Unilateral MAP: culminates with the pronouncement of the PCA granting or not granting relief (total or partial) to the international double taxation invoked by the taxpayer.
Bilateral MAP: culminates 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, as a consequence of the negotiation carried out between the CA of the Contracting States.
Among the different ways to conclude the MAP, we have the following:
Non-acceptance of the MAP.
The CA of the Contracting States reach an agreement, granting relief (total or partial) to the international double taxation invoked by the taxpayer.
The CA of the Contracting States do not reach an agreement.
There is no need to pronounce since the subject matter of the MAP controversy has ceased to exist.
The taxpayer has withdrawn its request, during the MAP process.
The taxpayer obtained relief (total or partial) to the invoked international double taxation through a domestic remedy.
Among others.