Mutual Agreement Procedure allows taxpayers to seek competent authority resolution of treaty-related taxation disputes by mutual agreement. Article 25 provides that a person believing 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 his State of residence or nationality within the prescribed time limit. The Competent Authority shall endeavour to resolve justified objections and, if necessary, reach a mutual agreement with the other State's Competent Authority to avoid taxation inconsistent with the Agreement; such agreements 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 seek competent authority resolution of treaty-related taxation disputes by mutual agreement.
Article 25 provides that a person believing 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 his State of residence or nationality within the prescribed time limit. The Competent Authority shall endeavour to resolve justified objections and, if necessary, reach a mutual agreement with the other State's Competent Authority to avoid taxation inconsistent with the Agreement; such agreements shall be implemented notwithstanding domestic time limits.
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