Mutual Agreement Procedure lets taxpayers ask competent authorities to resolve taxation contrary to a tax treaty within prescribed time limits. A person who considers that actions by one or both Contracting States result or will result in taxation contrary to the Agreement may present the case to ... Summary
Mutual Agreement Procedure lets taxpayers ask competent authorities to resolve taxation contrary to a tax treaty within prescribed time limits.
A person who considers that actions by one or both Contracting States result or will result in taxation contrary to the Agreement may present the case to the competent authority of his residence or nationality within three years of first notification; the competent authority shall, if the objection appears justified and it cannot 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 agreement reached shall be implemented notwithstanding domestic time limits.
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