Mutual Agreement Procedure: competent authorities must resolve treaty taxation disputes and eliminate double taxation by agreement. A resident or national who believes taxation contrary to the Convention may present the case to his competent authority within the prescribed time; the competent authority shall, if the objection appears justified and cannot be resolved domestically, seek a mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time limits, consult to resolve interpretive or application doubts, and may communicate directly or through a joint commission to eliminate double taxation.
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: competent authorities must resolve treaty taxation disputes and eliminate double taxation by agreement.
A resident or national who believes taxation contrary to the Convention may present the case to his competent authority within the prescribed time; the competent authority shall, if the objection appears justified and cannot be resolved domestically, seek a mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time limits, consult to resolve interpretive or application doubts, and may communicate directly or through a joint commission to eliminate double taxation.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.