The Mutual Agreement Procedure (MAP) is a process by which a taxpayer can ask two states (or #tax authorities) to reach an amicable agreement to eliminate double taxation as required by bilateral treaties, where the normal processes have failed.

According to #OECD statistics, in 2016-2024 there were only 19 cases between Italy and #Finland, of which only 3 closed.
https://www.oecd.org/en/data/datasets/mutual-agreement-procedure-statistics.html