Mutual Agreement Procedure facilitates competent authorities negotiating to prevent taxation inconsistent with the treaty through direct consultation and joint commissions. Mutual Agreement Procedure permits a person to present a case to the competent authority of his residence or nationality when taxation is or will be inconsistent with the Agreement; the competent authority shall endeavour to resolve justified objections by mutual agreement with the other Contracting State, implement any such agreement notwithstanding domestic time limits, and consult or form joint commissions to resolve interpretation doubts and eliminate double taxation where appropriate.
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 facilitates competent authorities negotiating to prevent taxation inconsistent with the treaty through direct consultation and joint commissions.
Mutual Agreement Procedure permits a person to present a case to the competent authority of his residence or nationality when taxation is or will be inconsistent with the Agreement; the competent authority shall endeavour to resolve justified objections by mutual agreement with the other Contracting State, implement any such agreement notwithstanding domestic time limits, and consult or form joint commissions to resolve interpretation doubts and eliminate double taxation where appropriate.
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