Este procedura amiabilă o soluție viabilă pentru evitarea dublei impuneri în România?
Is the Mutual Agreement Procedure a viable solution to avoid double taxation in Romania?

Summary/Abstract: The Mutual Agreement Procedure (MAP) is a tool provided by legislation to be used to avoid double taxation. In recent years, according to the available information on the website of Organization for Economic Co‑operation and Development (hereinafter referred to as the “OECD”), this tool is increasingly used in Europe and in OECD member countries to solve international tax disputes on double taxation. However, the Mutual Agreement Procedure is not very popular in Romania compared to other states of the European Union, and hence the natural question arises: is the Mutual Agreement Procedure a viable solution for avoiding double taxation? Better information for taxpayers on the MAP mechanism for solving double taxation issues, as well as increased involvement by the Romanian tax authorities in the correct use and resolution of MAP procedures, could contribute to a decrease in taxpayers’ reluctance to initiate such procedures, the final purpose being the implementation of the international fiscal principle of the avoidance of double taxation.

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