Israel Tax Agency Issues Circular Explaining Mutual Agreement Procedure Rules Under DTAs

The Israeli Tax Authority Aug. 17 issued Income Tax Circular No. 01/2023, explaining mutual agreement procedure (MAP) rules under DTAs. The circular explains: 1) the procedure for filing and initiating a MAP request, including for taxpayers applying to the Israeli competent authority for initiation of MAP; 2) rules applicable to individual cases, including a non-exhaustive list of scenarios for the competent authority to commence MAP proceedings, and the general three-year time limit for bringing MAP requests; 3) MAP rules at the request of a treaty state; 4) a requirement that the request include the relevant information and specify that the ...