Unilateral MAP
In case a taxpayer submits a MAP request to the PCA and the said authority considers as a consequence of its evaluation that it can find a solution to the case by itself, it shall issue a pronouncement by which it solves the MAP raised without involving the other Contracting State(s), granting or not granting relief (total or partial) to the international double taxation invoked by said taxpayer, all this without prejudice of notifying the noted Contracting State(s) of its pronouncement.
Likewise, when the CA of the other contracting state is able to find by itself the solution to the MAP raised in its jurisdiction, it will unilaterally adopt a solution and issue the corresponding pronouncement.
Bilateral MAP
In case a taxpayer submits a MAP request to the PCA and the PCA considers as a result of its evaluation that it cannot find a solution for the case on its own, it shall communicate to the CA of the other corresponding Contracting State such request, attaching the corresponding documentation, initiating the bilateral phase of the MAP.
Each of the CA will state its position with respect to the case in dispute of the MAP, initiating technical discussions and negotiation, if applicable, and may conclude the procedure with an agreement or a non-agreement, granting relief (total or partial) to the international double taxation invoked by the taxpayer, or not granting it.
It may be the case that the subject matter of the MAP affects not only two Contracting States, but that more Contracting States are involved, so that a multilateral MAP may be carried out. In such a case, the PCA will communicate the request to the other Contracting States involved.