Mutual Agreement Procedure requires authorities to resolve treaty interpretation and implementation issues and to communicate directly. The competent authorities must endeavour to resolve difficulties or doubts about implementation or interpretation of the tax treaty by mutual agreement, may agree on procedures for related provisions addressing allocation of taxing rights, and may communicate directly to reach such agreements.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Mutual Agreement Procedure requires authorities to resolve treaty interpretation and implementation issues and to communicate directly.
The competent authorities must endeavour to resolve difficulties or doubts about implementation or interpretation of the tax treaty by mutual agreement, may agree on procedures for related provisions addressing allocation of taxing rights, and may communicate directly to reach such agreements.
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