Mutual Agreement Procedure reservation: India limits application of MAP while notifying time limit provisions across tax treaties. India reserves that the first sentence of Article 16(1) will not apply to its Covered Tax Agreements and confirms that taxpayers may present MAP cases to the competent authority of their residence or nationality; the receiving competent authority will implement bilateral notification or consultation if it does not consider the objection justified. India also notifies which bilateral agreements contain MAP time limit provisions shorter than three years, which contain at least three year limits, and which listed agreements lack specified Article 16 procedural provisions.
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 reservation: India limits application of MAP while notifying time limit provisions across tax treaties.
India reserves that the first sentence of Article 16(1) will not apply to its Covered Tax Agreements and confirms that taxpayers may present MAP cases to the competent authority of their residence or nationality; the receiving competent authority will implement bilateral notification or consultation if it does not consider the objection justified. India also notifies which bilateral agreements contain MAP time limit provisions shorter than three years, which contain at least three year limits, and which listed agreements lack specified Article 16 procedural provisions.
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