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Mutual agreement procedure enables taxpayers to seek treaty-related taxation disputes resolved by competent authorities through binding agreements. A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of the State of residence or, where applicable, 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 taxation contrary to the Agreement, implement any agreement despite domestic time limits, resolve interpretive doubts, eliminate unintended double taxation, and communicate directly to reach agreement.
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 treaty-related taxation disputes resolved by competent authorities through binding agreements.
A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of the State of residence or, where applicable, 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 taxation contrary to the Agreement, implement any agreement despite domestic time limits, resolve interpretive doubts, eliminate unintended double taxation, and communicate directly to reach agreement.
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