Mutual agreement procedure preserves treaty taxation rights by enabling competent authorities to resolve treaty interpretation and double taxation disputes. Mutual agreement procedure allows a person alleging taxation inconsistent with the Agreement to present the case to the competent authority of residence or nationality within three years; the competent authority shall, if the objection seems justified and it cannot itself resolve the matter, seek a mutual agreement with the other territory's competent authority and implement any agreement notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretive or application doubts, consult to eliminate double taxation beyond the Agreement's provisions, communicate directly, and may hold oral exchanges via a commission of representatives.
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 preserves treaty taxation rights by enabling competent authorities to resolve treaty interpretation and double taxation disputes.
Mutual agreement procedure allows a person alleging taxation inconsistent with the Agreement to present the case to the competent authority of residence or nationality within three years; the competent authority shall, if the objection seems justified and it cannot itself resolve the matter, seek a mutual agreement with the other territory's competent authority and implement any agreement notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretive or application doubts, consult to eliminate double taxation beyond the Agreement's provisions, communicate directly, and may hold oral exchanges via a commission of representatives.
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