Mutual Agreement Procedure enables taxpayers to request competent authorities to resolve treaty taxation conflicts and eliminate double taxation. The Mutual Agreement Procedure allows a person alleging treaty-inconsistent taxation to present a case to the competent authority of residence or nationality; that authority must, if justified and unable to resolve the matter domestically, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the treaty, and any agreement reached is to be implemented notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretation or application issues, consult to eliminate double taxation beyond the treaty's text, communicate directly, and may use a Commission for oral exchanges to reach 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 enables taxpayers to request competent authorities to resolve treaty taxation conflicts and eliminate double taxation.
The Mutual Agreement Procedure allows a person alleging treaty-inconsistent taxation to present a case to the competent authority of residence or nationality; that authority must, if justified and unable to resolve the matter domestically, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the treaty, and any agreement reached is to be implemented notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretation or application issues, consult to eliminate double taxation beyond the treaty's text, communicate directly, and may use a Commission for oral exchanges to reach agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
