Background

The Mutual Agreement Program (MAP) is a service provided by the Canada Revenue Agency (CRA) to assist taxpayers in resolving cases of double taxation or taxation not in accordance with the provisions of a tax convention. The process requires co-operation from taxpayers to achieve the goal of resolving such cases.

Canada’s MAP program dates back to 1942, when it signed its first tax treaty with the United States, which contained a MAP provision. Published taxpayer guidance dates back to 1971, with the release of Information Circular 71-17. This information circular has been revised several times, and the CRA now operates under Information Circular 71-17R6, Competent Authority Assistance Under Canada’s Tax Conventions.

The MAP article in Canada’s conventions is a dispute resolution mechanism that allows authorized CRA officials to interact with foreign tax administrations to resolve issues of double taxation and taxation not in accordance with a convention. Under the article, residents in either country may request assistance resolving an issue covered by their convention. In Canada, the Minister of National Revenue authorizes senior CRA officials to try to resolve tax disputes under tax conventions that Canada has with other countries. These senior officials are referred to as the competent authority. A similar authorization usually takes place in Canada’s treaty partner countries.

The Competent Authority Services Division (CASD), which has responsibility for the MAP program, is part of the International and Large Business Directorate (ILBD) in the Compliance Programs Branch of the CRA. The Director of the CASD is an authorized competent authority for Canada and is responsible for cases involving double taxation and taxation not in accordance with a convention, as well as for the overall administration of the MAP program.

The latest report on the CRA’s MAP program is provided below:

Reports

2022 MAP Program Report (HTML)

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MAP guidelines

• IC71-17R5 Guidance on Competent Authority Assistance Under Canada's Tax Conventions
• Accelerated Competent Authority Procedure (ACAP)