Entitlement to invoke the MAP is expressed to be ‘notwithstanding the remedies provided by the national laws’ of the contracting states. It is, in consequence, an additional process available to taxpayers and not a substitute for the appeal process or any other domestic law dispute resolution mechanisms. The practice adopted by HMRC in this respect is explained in the International Tax Manual:

‘Where a case has been settled under the UK’s judicial process before it is presented for MAP, the UK competent authority would expect, on request, to take the matter up under MAP. The UK considers that both a court and a tribunal form part of the judicial process.

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