Mutual Agreement Procedure enables taxpayers to seek competent-authority resolution of treaty taxation conflicts through direct bilateral negotiation. Mutual Agreement Procedure allows a person claiming taxation inconsistent with the Convention to present the case to the competent authority of his residence or nationality; the competent authority shall endeavour to resolve justified objections by mutual agreement with the other State's competent authority to avoid treaty-inconsistent taxation, implement any agreement notwithstanding domestic time limits, resolve interpretation or application difficulties, consult to eliminate double taxation not provided for in the Convention, and communicate directly including via a joint commission.
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 enables taxpayers to seek competent-authority resolution of treaty taxation conflicts through direct bilateral negotiation.
Mutual Agreement Procedure allows a person claiming taxation inconsistent with the Convention to present the case to the competent authority of his residence or nationality; the competent authority shall endeavour to resolve justified objections by mutual agreement with the other State's competent authority to avoid treaty-inconsistent taxation, implement any agreement notwithstanding domestic time limits, resolve interpretation or application difficulties, consult to eliminate double taxation not provided for in the Convention, and communicate directly including via a joint commission.
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