Mutual agreement procedure enables taxpayers to seek competent authority negotiation to resolve taxation inconsistent with a tax treaty. The mutual agreement procedure lets a person who believes actions by one or both Contracting States cause taxation inconsistent with the Agreement present the case to the competent authority of residence or nationality, which shall seek a mutual agreement with the other State's competent authority to avoid such taxation, implement any agreement notwithstanding domestic time limits, and communicate directly or via a Commission to resolve interpretation or application difficulties and eliminate double taxation.
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 seek competent authority negotiation to resolve taxation inconsistent with a tax treaty.
The mutual agreement procedure lets a person who believes actions by one or both Contracting States cause taxation inconsistent with the Agreement present the case to the competent authority of residence or nationality, which shall seek a mutual agreement with the other State's competent authority to avoid such taxation, implement any agreement notwithstanding domestic time limits, and communicate directly or via a Commission to resolve interpretation or application difficulties and eliminate double taxation.
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