Mutual Agreement Procedure enables taxpayers to seek resolution of treaty-based tax mismatches through competent authority negotiations. A person who considers that actions by one or both Contracting States result in taxation inconsistent with the Convention may present the case to the competent authority of his residence or nationality within three years of first notification. The competent authority shall endeavour to resolve justified objections by mutual agreement with the other State's competent authority to avoid such taxation, implement any agreement notwithstanding domestic time limits, consult to eliminate double taxation in uncaptured cases, 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 resolution of treaty-based tax mismatches through competent authority negotiations.
A person who considers that actions by one or both Contracting States result in taxation inconsistent with the Convention may present the case to the competent authority of his residence or nationality within three years of first notification. The competent authority shall endeavour to resolve justified objections by mutual agreement with the other State's competent authority to avoid such taxation, implement any agreement notwithstanding domestic time limits, consult to eliminate double taxation in uncaptured cases, and communicate directly including via a joint commission.
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