Mutual Agreement Procedure enables taxpayers to seek competent authority resolution of treaty taxation conflicts and avoid double taxation. The Mutual Agreement Procedure allows a person who believes actions by one or both Contracting States cause taxation inconsistent with the Agreement to present the case to the competent authority of the State of residence or nationality within three years of first notification. The competent authorities must endeavour to resolve justified objections by mutual agreement to avoid treaty-inconsistent taxation, implement agreements notwithstanding domestic time limits, resolve interpretive difficulties, eliminate double taxation in uncovered cases, communicate directly, and use a Commission for oral exchanges when advisable.
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 and avoid double taxation.
The Mutual Agreement Procedure allows a person who believes actions by one or both Contracting States cause taxation inconsistent with the Agreement to present the case to the competent authority of the State of residence or nationality within three years of first notification. The competent authorities must endeavour to resolve justified objections by mutual agreement to avoid treaty-inconsistent taxation, implement agreements notwithstanding domestic time limits, resolve interpretive difficulties, eliminate double taxation in uncovered cases, communicate directly, and use a Commission for oral exchanges when advisable.
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