Website Last updated:

May 15, 2026

This guide outlines the Mutual Agreement Procedure (MAP), a mechanism under the UAE's Double Tax Agreements (DTAs) to resolve disputes from taxation not in accordance with a DTA. It explains MAP's applicability, such as in transfer pricing cases causing double taxation. The guide details the process for filing a MAP claim with the UAE Competent Authority, including required information and timelines. It describes the bilateral negotiation phase and clarifies that any agreement reached is implemented upon taxpayer acceptance, potentially involving a voluntary disclosure, providing a clear path for tax dispute resolution.

United Arab Emirates Mutual Agreement Procedure Guidance

1. Introduction

1.1. What is MAP?

2. Background

2.1. Double Tax Agreements
2.2. Legal basis
2.3. Competent Authority
2.4. Federal Tax Authority

3. MAP process

3.1. Step 1: Eligibility
1. 3.1.1. When is MAP available?
2. 3.1.2. Domestic/Anti-abuse provisions
3. 3.1.3. Multilateral disputes
4. 3.1.4. Bona-fide self-initiated adjustments
5. 3.1.5. Surrendering access to MAP
6. 3.1.6. Time limit
7. 3.1.7. Domestic remedies
8. 3.1.8. Impact of domestic legal rulings
3.2. Step 2: Filing a MAP claim
1. 3.2.1. What information is required for a MAP claim?
2. 3.2.2. Multi-year periods
3. 3.2.3. Who should the MAP claim be submitted to?
3.3. Step 3: Assessment of MAP claim
3.4. Step 4: Objection justified
1. 3.4.1. Step 4 a): Unilateral relief
2. 3.4.2. Step 4 b): Bilateral Negotiation
3. 3.4.3. Taxpayer communication
3.5. Step 5: Outcome
1. 3.5.1. Competent Authority Agreement
2. 3.5.2. Taxpayer acceptance of MAP Agreement
3. 3.5.3. Taxpayer rejection of MAP Agreement
4. 3.5.4. No Competent Authority Agreement
5. 3.5.5. Timeline
6. 3.5.6. Withdrawal of MAP claim
7. 3.5.7. Arbitration
8. 3.5.8. Penalties
9. 3.5.9. Tax

4. Key take-aways for taxpayers in the MAP process

Introduction

What is MAP?

The Mutual Agreement Procedure ('MAP') is a process by which the United Arab Emirates ('UAE') and other contracting states in Double Tax Agreements ('DTA') seek to resolve international tax disputes, which result, or will result in taxation, that is not in accordance with the DTA. A MAP may also be sought where there is an issue of interpretation or application of the relevant DTA and where double taxation arises for cases not provided for in the relevant DTA.

The purpose of this guidance is to outline to taxpayers:

What is MAP?
When is MAP applicable?
What information is required for a MAP claim?
What is the process for MAP?

Background

Double Tax Agreements

The UAE has over 100 in force DTAs with other contracting states around the globe. In force DTAs are legally binding international agreements between the UAE and the other contracting state.

A DTA is an international agreement signed by two countries for the avoidance of double taxation and the prevention of fiscal evasion of taxes on income and capital. DTAs provide a means of settling the most common problems that arise in the field of international double taxation, on a uniform basis.

Contents

Introduction

What is MAP?

Background

Double Tax Agreements