BTPA definition
Examples of BTPA in a sentence
Underlined text below indicates information pertaining to BTPA or MTPA as the case may be.
Each TPA is unique, and each will set out the particular requirements of the TPA Notice, such as content, scope, filing date and whether joint TPA Notices are required in the case of a BTPA or MTPA.
In the case of a BTPA or MTPA, the confidentiality provision in the relevant DTA will also apply.
The terms of this TPA are consistent with the related competent authority agreement reached between the Jamaican competent authority and the [NAMES OF THE RELEVANT FOREIGN COMPETENT AUTHORITIES] dated [DATE OF THE BTPA OR MTPA] pursuant to Article [NUMBER] of the [NAME OF THE RELEVANT DTAs].
The TPA programme achieves maximum benefits for the taxpayer when the competent authorities of two or more countries reach a BTPA or MTPA (see Appendix VIII – Competent Authority Considerations for more information on the BTPA or MTPA process).
However, if double taxation occurs as a result of the taxpayer withdrawing from the BTPA or MTPA process, the competent authorities' position to address the double taxation under the mutual agreement procedure (MAP) article of the relevant DTA may remain the same as the final TPM agreed amongst the competent authorities.
If for any reason a BTPA or MTPA has not been concluded, and taxpayer and TAJ have concluded a unilateral TPA, the taxpayer retains the right to pursue the MAP article available under the relevant DTA.
The purpose of pursuing a BTPA or MTPA is to avoid double taxation in respect of transactions entered into between a taxpayer and non-resident connected person.