Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

Eswatini (Kingdom of)

Recent developments relating to MAP in Eswatini prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• No developments were reported

Other developments relating to MAP

• No developments were reported

Latest Action 14 Peer Review report

Eswatini is yet to be peer reviewed under Action 14.

Tax treaty network of Eswatini

• seven treaties, applicable to seven jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: signed.

Table 1. State of play of Eswatini's tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
6	0	1

Source: OECD

Eswatini's MAP programme

Organisation of competent authority function

• four persons:

  • one head of unit

  • three persons working on MAP cases (all of which work on other tasks as well):

    • two persons work on attribution/allocation cases and one person works on other cases.

• contact persons for MAP requests:

  • Ms Nomcebo Marrengane Head of Legal Services Delegated Competent Authority Portion 419 of Farm 50, Along MR103, Ezulwini P.O. Box 5628 Mbabane, Eswatini Tel: [phone] | Direct: [phone] | Mobile: [phone] Fax: [phone] E-mail: [e-mail] | Web: www.ers.org.sz.

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	No MAP guidance published	-
MAP profile	No MAP profile published	-

Overview of Eswatini's MAP Statistics for 2022

Eswatini did not report any MAP cases in its 2022 MAP Statistics.

Please refer to https://www.oecd.org/tax/dispute/map-statistics-eswatini.pdf for details with respect to Eswatini's MAP Statistics.