TPG2017 Chapter IV Annex II paragraph 79

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A tax administration may cancel a MAP APA (either unilaterally or by mutual agreement) if it is established that one of the following situations has arisen:
a) There was a misrepresentation, mistake or omission that was not attributable to the neglect, carelessness, or wilful default of a taxpayer when filing the MAP APA request and submission, the annual reports, or other supporting documentation or in supplying any related information; or
b) The participating taxpayer(s) failed to materially comply with any term or condition of the MAP APA; or
c) There was a material breach of one or more of the critical assumptions; or
d) There was a change in tax law, including a treaty provision materially relevant to the MAP APA; and it has not proved possible to revise the agreement (see paragraphs 80-82 below) to take account of the changed circumstances.






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