Mutual agreement procedure enables taxpayers to seek competent authority resolution to avoid treaty-inconsistent taxation through bilateral agreement. The Mutual Agreement Procedure allows a person who considers they face taxation inconsistent with the Agreement to present their case to the competent authority of their State of residence or nationality within the Treaty's three year time limit; that authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other Contracting State to avoid taxation contrary to the Agreement, implement any agreement notwithstanding domestic time limits, and consult or convene a Commission to resolve interpretive or application difficulties and eliminate double taxation.
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 to avoid treaty-inconsistent taxation through bilateral agreement.
The Mutual Agreement Procedure allows a person who considers they face taxation inconsistent with the Agreement to present their case to the competent authority of their State of residence or nationality within the Treaty's three year time limit; that authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other Contracting State to avoid taxation contrary to the Agreement, implement any agreement notwithstanding domestic time limits, and consult or convene a Commission to resolve interpretive or application difficulties and eliminate double taxation.
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