Mutual Agreement Procedure enables competent authorities to resolve taxation not in accordance with a tax treaty through negotiation. The Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention to present the case to the competent authority of residence or nationality within three years of first notification. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to resolve the case by mutual agreement with the other State's competent authority to avoid taxation contrary to the Convention.
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 competent authorities to resolve taxation not in accordance with a tax treaty through negotiation.
The Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention to present the case to the competent authority of residence or nationality within three years of first notification. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to resolve the case by mutual agreement with the other State's competent authority to avoid taxation contrary to the Convention.
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 
