Mutual Agreement Procedure enables taxpayers to seek competent authority negotiations to avoid treaty-inconsistent taxation. The Mutual Agreement Procedure permits a taxpayer to present to the competent authority a case that a Contracting State's actions result or will result in taxation inconsistent with the treaty, irrespective of domestic remedies and within a prescribed time limit. If the authority deems the objection justified and cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to avoid improper taxation; competent authorities must endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation, and may communicate directly to reach 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 enables taxpayers to seek competent authority negotiations to avoid treaty-inconsistent taxation.
The Mutual Agreement Procedure permits a taxpayer to present to the competent authority a case that a Contracting State's actions result or will result in taxation inconsistent with the treaty, irrespective of domestic remedies and within a prescribed time limit. If the authority deems the objection justified and cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to avoid improper taxation; competent authorities must endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation, and may communicate directly to reach agreements.
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