Mutual agreement procedure secures coordinated resolution by competent authorities to eliminate treaty-inconsistent taxation. A taxpayer may present a case to the competent authority of his residence or nationality if actions of one or both Contracting States result in taxation contrary to the Agreement, within three years of first notification. The competent authority shall, if justified and unable to resolve the matter domestically, seek a mutual agreement with the other State's competent authority to eliminate such taxation, and any agreement reached must 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 secures coordinated resolution by competent authorities to eliminate treaty-inconsistent taxation.
A taxpayer may present a case to the competent authority of his residence or nationality if actions of one or both Contracting States result in taxation contrary to the Agreement, within three years of first notification. The competent authority shall, if justified and unable to resolve the matter domestically, seek a mutual agreement with the other State's competent authority to eliminate such taxation, and any agreement reached must be implemented notwithstanding domestic time limits.
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