Bilateral APAs and mutual agreement procedures (MAPs): why the interest due may differ
Interest on tax due and late payment interest also often play a role in the adjustment or reassessment of the profit. Sates involved maintain different national rules on interest, which can result in a considerable interest expense during the mutual agreement procedure and/or the run-up period to the conclusion of a BAPA. At the time of writing, the Netherlands charges 8% (!) interest on any tax due, which can add up to quite a hefty sum.