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A POP can be invoked by taxpayers so that one country, in agreement with the other country, can eliminate cases of double taxation resulting from the actions of the tax administration in the other country. For more information on applying for a POP and exceptions for individuals, see Chapter 3.4 of the Tax Administration Guidelines on the Procedure for Mutual Agreement in the Case of International Tax Disputes. The process of mutual unification (POP) remains the most widely used way and the best way to eliminate double taxation. The effective use of PPIs by different instruments has been of interest to the OECD and the EU for more than 20 years. According to bePS, the number of double taxes is increasing and the number of POPs continues to increase. There is a growing emphasis on ensuring better dispute resolution techniques to more effectively eliminate double taxation. This article describes some of the features of the instruments currently available. In addition, it is important to consider the impact of a national transaction agreement on the possibility of obtaining double taxation relief in the POP process at a later date. The internal resolution of disputes related to cross-border transactions may, in practice, limit the ability of the competent authority, on the other side of operations, to grant facilities for double taxation. This is mainly due to the fact that such comparisons restrict the negotiations of the competent authorities: the position agreed by the taxpayer with one tax authority may not be acceptable to others. For U.S.-based taxpayers, for example, a national comparison without POPs can be particularly damaging, as taxpayers must prove that they have exhausted all effective and practical remedies to challenge their taxes or that their foreign tax credits are being denied by U.S. tax authorities.

The Arbitration Convention of the European Union (EU) establishes a procedure for settling transfer pricing disputes for EU member states. This procedure may apply in cases of double taxation between companies in different EU Member States. In addition to these developments, the European Union has proposed a new directive on the mechanisms for resolving disputes on double taxation in the European Union, which aims to resolve cases of double taxation within the EU by mutual agreement between member states. This could become, when the time comes, another instrument that EU taxpayers will be able to access when the time comes. [3] The POP is an informal procedure to address cross-border problems of economic double taxation. Unlike a court proceeding, POPs proceedings tend to be less costly, less time-consuming and involve the taxpayer, albeit informally, in the attempt to resolve cross-border tax issues. Some of the benefits to taxpayers using the MAP program are that before applying for MAP, the individual or company should speak with the appropriate authorities to determine if the issue can be resolved as part of the mutual agreement process. The tax administration advises and advises on the choice of the appropriate procedure.