Mutual Agreement Procedure enables taxpayers to seek competent authority resolution of treaty taxation disputes and eliminate double taxation. The Mutual Agreement Procedure permits a person who believes taxation results or will result contrary to the Agreement to present the case to the competent authority of his State of residence or nationality within three years of notification. The competent authority shall, if it finds the objection justified and cannot itself resolve it, seek a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Agreement, implement any agreement notwithstanding domestic time limits, consult to resolve interpretative difficulties, communicate directly, and convene a Commission for oral exchanges if advisable.
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 competent authority resolution of treaty taxation disputes and eliminate double taxation.
The Mutual Agreement Procedure permits a person who believes taxation results or will result contrary to the Agreement to present the case to the competent authority of his State of residence or nationality within three years of notification. The competent authority shall, if it finds the objection justified and cannot itself resolve it, seek a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Agreement, implement any agreement notwithstanding domestic time limits, consult to resolve interpretative difficulties, communicate directly, and convene a Commission for oral exchanges if advisable.
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