Mutual Agreement Procedure: competent authorities must endeavour to resolve treaty interpretation or application disputes cooperatively. The Agreement requires that the competent authorities of the Contracting States endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the treaty, creating a bilateral administrative mechanism for cooperative resolution of interpretive and application disputes under the Double Tax Avoidance Agreement.
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: competent authorities must endeavour to resolve treaty interpretation or application disputes cooperatively.
The Agreement requires that the competent authorities of the Contracting States endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the treaty, creating a bilateral administrative mechanism for cooperative resolution of interpretive and application disputes under the Double Tax Avoidance Agreement.
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