Article 25
Article 25 - Mutual Agreement Procedure (MAP)
MAP allows the competent authorities of India and Turkey to resolve disputes - particularly transfer pricing disputes - by mutual agreement.
Where a taxpayer believes that the actions of either State result in taxation not in accordance with the treaty, MAP can be invoked. The competent authority application must usually be made within 3 years of the first notification of the inconsistent action. India's competent authority is the Joint Secretary (FT&TR) in the CBDT.
Resolution time: MAP cases historically took 2-4 years. Following the BEPS Action 14 framework and the MLI, mandatory binding arbitration has become available for some India treaties (notably with Japan, Singapore, UK - subject to specific reservations).