Mutual agreement procedure: taxpayer may notify competent authority to resolve taxation contrary to the treaty through mutual agreement between authorities. The Mutual Agreement Procedure allows a resident or qualifying national to present to the competent authority a case alleging taxation not in accordance with the DTAA within a three-year time limit; the competent authorities shall endeavour to resolve justified objections by mutual agreement, implement any agreement notwithstanding domestic time limits, consult to resolve interpretation issues, communicate directly, and, if needed, hold oral exchanges through a Commission of representatives.
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: taxpayer may notify competent authority to resolve taxation contrary to the treaty through mutual agreement between authorities.
The Mutual Agreement Procedure allows a resident or qualifying national to present to the competent authority a case alleging taxation not in accordance with the DTAA within a three-year time limit; the competent authorities shall endeavour to resolve justified objections by mutual agreement, implement any agreement notwithstanding domestic time limits, consult to resolve interpretation issues, communicate directly, and, if needed, hold oral exchanges through a Commission of representatives.
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