Mutual Agreement Procedure enables taxpayers to seek relief when taxation conflicts with treaty provisions through competent authorities' consultations. Where a person considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement, the person ... Summary
Mutual Agreement Procedure enables taxpayers to seek relief when taxation conflicts with treaty provisions through competent authorities' consultations.
Where a person considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement, the person may present the case to the competent authority of the State of residence or nationality within the prescribed time limit. 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 competent authority of the other Contracting State and implement any agreement notwithstanding domestic time limits.
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