Mutual Agreement Procedure enables competent authorities to resolve cross-border tax disagreements and prevent taxation not in accordance with treaty terms. The Mutual Agreement Procedure permits a person who believes taxation is not in accordance with the Agreement to present the case to the relevant competent authority, which shall, if the objection appears justified and it cannot resolve the matter domestically, endeavour to resolve the case by mutual agreement with the other Contracting Party's competent authority and implement any agreement 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 enables competent authorities to resolve cross-border tax disagreements and prevent taxation not in accordance with treaty terms.
The Mutual Agreement Procedure permits a person who believes taxation is not in accordance with the Agreement to present the case to the relevant competent authority, which shall, if the objection appears justified and it cannot resolve the matter domestically, endeavour to resolve the case by mutual agreement with the other Contracting Party's competent authority and implement any agreement notwithstanding domestic time limits.
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