United Kingdom. Total MAP Caseload. Average time needed to close MAP cases (in months)

Transcription

1 United Kingdom Total MAP Caseload Cases started before 1 January start inventory Cases started Cases closed 2017 end inventory Start inventory on Cases started Cases closed End inventory on Cases started as from 1 January start inventory Cases started Cases closed 2017 end inventory Cases started before 1 January 2016 Cases started as from 1 January 2016 Average time needed to close MAP cases (in months) Cases started before 1 January 2016 Average time Note: the average time taken to close MAP cases that started before 1 January 2016 was computed by applying the following rules: (i) start date: the date when the MAP request was received; and (ii) end date: the competent authorities concerned reached a formal. Where competent authorities require taxpayers to confirm their acceptance of the reached, the end date is computed as the date the competent authorities have received this confirmation. Cases started as from 1 January 2016 Start to End Receipt to Start Start to Milestone 1 Milestone 1 to End Note: the average times to close MAP cases that started as from 1 January 2016 were computed according to the MAP statistics reporting framework available at United Kingdom MAP Statistics Page 1/9

2 Overview of MAP partners (only for cases started as from 1 January 2016) Note: the MAP cases started before 1 January 2016 and closed in 2017 are not shown in these graphs Canada Denmark France Germany India Italy Spain United States Treaty Partners (de minimis rule applies) Cases in 2017 start inventory + cases started in 2017 Cases closed in Belgium Canada Germany India Italy Netherlands New Zealand Spain United States Treaty Partners (de minimis rule Cases in 2017 start inventory + cases started in 2017 Cases closed in 2017 applies) Treaty Partners (Others) The label "Treaty Partners (de minimis rule applies)" applies to treaty partners with which the number of cases in start inventory plus the number of cases started is at least 5. The relevant MAP statistics are aggregated under this category. The label "Treaty Partners (Others)" applies to treaty partners that are not reporting MAP statistics for the reporting period. The relevant MAP statistics are aggregated under this category. United Kingdom MAP Statistics Page 2/9

3 MAP Outcomes 3% 1% 1% 3%2% 2% 2% denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted 38% resolved via domestic remedy fully double taxation / fully resolving 47% partially double taxation / partially resolving that there is no no including to disagree 1% any other outcome Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving that there is no no including to disagree any other outcome Total (all) Cases started before 1 January Cases started as from 1 January (all) Cases started before 1 January Cases started as from 1 January All cases United Kingdom MAP Statistics Page 3/9

4 Annex A MAP Statistics Reporting for the 2017 Reporting Period (1 January 2017 to 31 December 2017) for Pre-2016 Cases United Kingdom category of cases no. of pre-2016 cases in MAP inventory on 1 January 2017 denied MAP access objection is not justified withdrawn by taxpayer number of pre-2016 cases closed during the reporting period by outcome: unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving with partially double taxation / partially resolving with that there is no with no including to disagree any other outcome no. of pre cases remaining in on MAP inventory on 31 December 2017 average time taken (in months) for closing pre cases during the reporting period Row 1 Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 10 Column 11 Column 12 Column 13 Column 14 Attribution/ Allocation Row 2 Others Row 3 Total ) MAP cases recorded in this table meet the definition of MAP case and use the counting method as outlined in Annex D (section 1) of the report "MAP Statistics Reporting Framework" commissioned by the Committee on Fiscal Affairs, published on 1 September ) The average time taken to close pre-2016 cases was computed by applying the following rules: (i) start date: the date when the MAP request was received; and (ii) end date: the competent authorities concerned reached a formal. Where competent authorities require taxpayers to confirm their acceptance of the reached, the end date is computed as the date the competent authorities have received this confirmation. United Kingdom MAP Statistics Page 4/9

5 Table 1: Attribution / Allocation MAP Cases number of post-2015 cases closed during the reporting period by outcome: Treaty Partner 2015 cases in MAP inventory on 1 January cases started during the reporting period denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation eliminated / fully resolving partially double taxation / partially resolving taxation not in with that there is no taxation not in with no including to disagree any other outcome 2015 cases remaining in MAP inventory on 31 December 2017 Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 10 Column 11 Column 12 Column 13 Column 14 Row 1 Canada Denmark France Germany India Italy Spain United States Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Notes 1) MAP cases recorded in this table meet the definition of MAP case and use the counting method as outlined in Annex D (section 1) of the report "MAP Statistics Reporting Framework" commissioned by the Committee on Fiscal Affairs, published on 1 September ) The number of post-2015 cases on 1 January 2017 in the table above is different from 2016 MAP statisticus due to the followings: (i) One treaty partner: the number of post-2015 cases in MAP inventory on 1 January 2017 is five more than the number of post-2015 cases reported in MAP inventory on 31 December 2016 because the United Kingdom and its treaty partner have determined that five cases with 2016 start dates inadvertently were not included in statistical reporting for 2016; (ii) Treaty Partner (de minimis): The number of post-2015 cases in MAP inventory on 1 January 2017 includes one fewer case than recorded in the number of post-2015 cases reported in MAP inventory on 31 December 2016, as this case was inadvertently recorded as type attribution allocation and should have been recorded as type other. (iii) Treaty Partner (Others): The number of post-2015 cases in MAP inventory on 1 January 2017 is one less (i.e. total equals 0) than the number of post-2015 cases reported in MAP inventory on 31 December 2016 because the one post-2015 case was settled in 2016, under category 'Denied MAP access', but had not been notified to the United Kingdom until after the submission of the 2016 statistics. United Kingdom MAP Statistics Page 5/9

6 Treaty Partner 2015 cases in MAP inventory on 1 January cases started during the reporting period denied MAP access objection is withdrawn by not justified taxpayer Table 2: Other MAP Cases number of post-2015 cases closed during the reporting period by outcome unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving taxation not in with that there is no with no including to disagree Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column 10 Column 11 Column 12 Column 13 Column 14 Row 1 Belgium Canada Germany India Italy Netherlands New Zealand Spain United States Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total ) MAP cases recorded in this table meet the definition of MAP case and use the counting method as outlined in Annex D (section 1) of the report "MAP Statistics Reporting Framework" commissioned by the Committee on Fiscal Affairs, published on 1 September ) The number of post-2015 cases on 1 January 2017 in the table above is different from 2016 MAP statisticus due to the followings: (i) One Treaty Partner: The number of post-2015 cases in MAP inventory on 1 January 2017 is two more than the number of post-2015 cases reported in MAP inventory on 31 December 2016 because the Unitted Kingdom and its treaty partner have determined that two cases with 2016 start dates inadvertently were not included in statistical reporting for 2016; and (ii) Treaty Partner (de minimis): The number of post-2015 cases in MAP inventory on 1 January 2017 includes one additional case not recorded in the number of post-2015 cases reported in MAP inventory on 31 December 2016, as this case was inadvertently recorded as type attribution allocation and should have been recorded as type other. (iii) Treaty Partner (Others): The number of post-2015 cases in MAP inventory on 1 January 2017 is one less (i.e. total equals 0) than the number of post-2015 cases reported in MAP inventory on 31 December 2016 because the one case was actually started before 1 January 2016, and so should not have been included in the statistical reporting for any other outcome 2015 cases remaining in MAP inventory on 31 December 2017 United Kingdom MAP Statistics Page 6/9

7 "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Column 5 Row 1 Canada Denmark France Germany India Italy Spain United States Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Treaty Partner Table 1: Attribution / Allocation MAP Cases average time taken (in months) for post-2015 cases from: Total Average Time MAP cases recorded in this table meet the definition of MAP case and use the counting method as outlined in Annex D (section 1) of the report "MAP Statistics Reporting Framework" commissioned by the Committee on Fiscal Affairs, published on 1 September United Kingdom MAP Statistics Page 7/9

8 "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Column 5 Row 1 Belgium Canada Germany India Netherlands New Zealand United States Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Treaty Partner Table 2: Other MAP Cases average time taken (in months) for post-2015 cases from: Total Average Time MAP cases recorded in this table meet the definition of MAP case and use the counting method as outlined in Annex D (section 1) of the report "MAP Statistics Reporting Framework" commissioned by the Committee on Fiscal Affairs, published on 1 September United Kingdom MAP Statistics Page 8/9

9 "Start" to "End" Table 3: All MAP Cases average time taken (in months) for post-2015 cases from: Receipt of taxpayer's MAP request to "Start" "Start" to Milestone 1 Milestone 1 to "End" Column 1 Column 2 Column 3 Column 4 Row 1 Total Average Time MAP cases recorded in this table meet the definition of MAP case and use the counting method as outlined in Annex D (section 1) of the report "MAP Statistics Reporting Framework" commissioned by the Committee on Fiscal Affairs, published on 1 September United Kingdom MAP Statistics Page 9/9