Mutual Agreement Procedure enables taxpayers to seek competent authorities' agreement to resolve treaty-related taxation mismatches. A taxpayer who considers that actions by one or both Contracting States result in taxation inconsistent with the Agreement may present the case to the competent authority of his residence or nationality; the competent authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Agreement, and any resulting agreement shall be implemented notwithstanding domestic time limits.
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 authorities' agreement to resolve treaty-related taxation mismatches.
A taxpayer who considers that actions by one or both Contracting States result in taxation inconsistent with the Agreement may present the case to the competent authority of his residence or nationality; the competent authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Agreement, and any resulting agreement shall be implemented notwithstanding domestic time limits.
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