Mutual Agreement Procedure: competent authorities negotiate to remedy treaty-inconsistent taxation, eliminate double taxation and implement agreed solutions. A person may present to the competent authority of his State of residence or nationality a case that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention, within the prescribed presentation period. If the competent authority considers the objection justified and cannot resolve it domestically, it shall seek a Mutual Agreement Procedure with the other State's competent authority to avoid treaty-inconsistent taxation; any agreement reached is to be implemented notwithstanding domestic time limits. Competent authorities shall endeavour to resolve interpretation or application doubts, consult to eliminate double taxation, communicate directly, and may convene a Commission for oral exchanges.
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 negotiate to remedy treaty-inconsistent taxation, eliminate double taxation and implement agreed solutions.
A person may present to the competent authority of his State of residence or nationality a case that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention, within the prescribed presentation period. If the competent authority considers the objection justified and cannot resolve it domestically, it shall seek a Mutual Agreement Procedure with the other State's competent authority to avoid treaty-inconsistent taxation; any agreement reached is to be implemented notwithstanding domestic time limits. Competent authorities shall endeavour to resolve interpretation or application doubts, consult to eliminate double taxation, communicate directly, and may convene a Commission for oral exchanges.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.