Once a pronouncement has been issued unilaterally resolving the MAP or an agreement has been reached between the CA of the Contracting States, the taxpayer must expressly accept or not such pronouncement and/or agreement adopted by the CA. After the taxpayer’s acceptance of the aforementioned pronouncement and/or agreement, and there being no administrative or judicial appeals on the subject matter of the dispute resolved through the MAP, its implementation proceeds.
If no acceptance or no express acceptance is expressed, the agreement will not be implemented.