Within the past twelve-month period, the Maldives tax authority has published transfer pricing regulations, country-by-country reporting regulations, and introduced the mutual agreement procedure as a mechanism for tax dispute resolution – all in an effort to align its domestic laws with the OECD/G20 Base Erosion Profit Shifting (BEPS) plan.
In addition, Third Amendment to the Tax Administration Regulation granted Maldives Inland Revenue Authority (MIRA) the right to enter into APAs with taxpayers or other tax administrations with the purpose of providing certainty and clarity in the domain of transfer pricing. The Advance Pricing Regulation (2021/R-42) was published by MIRA on 16 March 2021 stipulating the procedures to be followed for entering into an APA with MIRA.
Given India’s historic connect with Maldives and the potential in rapid expansion of India’s business and investment in Maldives, it is time the two countries entered into a DTAA so that the Indian business community is able to reap maximum benefit arising out of the introduction of APA programme in Maldives.
In order to have deeper understanding of the issue, please refer to my article published on Taxsutra on 28th April, 2021 titled 'Introduction of APA programme in Maldives & India’s Connect with Maldives' which is available at the following link:
https://www.taxsutra.com/tp/experts-corner/introduction-apa-programme-maldives-indias-connect-maldives
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