Mutual agreement procedure enables competent authorities to resolve cross-border tax inconsistencies and avoid double taxation through consultation. A resident who considers that actions by one or both Contracting States result in taxation not in accordance with the Agreement may present the case to the competent authority of his State of residence within the prescribed time limit; that authority shall endeavour, if the objection appears justified and it cannot itself resolve the matter, to obtain a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Agreement, implement any agreement notwithstanding national time limits, and consult or communicate directly to resolve interpretive doubts or eliminate double taxation.
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Provisions expressly mentioned in the judgment/order text.
Mutual agreement procedure enables competent authorities to resolve cross-border tax inconsistencies and avoid double taxation through consultation.
A resident who considers that actions by one or both Contracting States result in taxation not in accordance with the Agreement may present the case to the competent authority of his State of residence within the prescribed time limit; that authority shall endeavour, if the objection appears justified and it cannot itself resolve the matter, to obtain a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Agreement, implement any agreement notwithstanding national time limits, and consult or communicate directly to resolve interpretive doubts or eliminate double taxation.
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