Mutual Agreement Procedure enables competent authorities to directly resolve treaty interpretation and implementation disputes by agreement. Where difficulties or doubts arise about implementation or interpretation of the tax treaty, the competent authorities shall endeavour to resolve the matter by mutual agreement, may communicate directly for that purpose, and may mutually agree procedures to be applied in relation to other treaty provisions to coordinate resolution of such disputes.
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 competent authorities to directly resolve treaty interpretation and implementation disputes by agreement.
Where difficulties or doubts arise about implementation or interpretation of the tax treaty, the competent authorities shall endeavour to resolve the matter by mutual agreement, may communicate directly for that purpose, and may mutually agree procedures to be applied in relation to other treaty provisions to coordinate resolution of such disputes.
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