Mutual agreement procedure allows taxpayers to submit treaty disputes to competent authorities for resolution and binding implementation. Article 25 provides that 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 residence or nationality within the prescribed time limit. 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 shall 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 allows taxpayers to submit treaty disputes to competent authorities for resolution and binding implementation.
Article 25 provides that 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 residence or nationality within the prescribed time limit. 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 shall be implemented notwithstanding domestic time limits.
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