Mutual Agreement Procedure: competent authorities must resolve treaty taxation disputes and implement agreements despite domestic time limits. Article 25 permits a person alleging taxation inconsistent with the Agreement to present a case to the competent authority of his residence or nationality within the specified three year period; the competent authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation contrary to the Agreement, and any such agreement must be implemented notwithstanding domestic time limits. Competent authorities may also consult and communicate directly to resolve interpretation questions and eliminate unprovided double taxation.
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: competent authorities must resolve treaty taxation disputes and implement agreements despite domestic time limits.
Article 25 permits a person alleging taxation inconsistent with the Agreement to present a case to the competent authority of his residence or nationality within the specified three year period; the competent authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation contrary to the Agreement, and any such agreement must be implemented notwithstanding domestic time limits. Competent authorities may also consult and communicate directly to resolve interpretation questions and eliminate unprovided double taxation.
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