Mutual agreement procedure: taxpayers may seek competent authority negotiation to prevent taxation contrary to the tax convention. A mutual agreement procedure allows a person who believes actions by one or both Contracting States produce taxation inconsistent with the Convention to present the case to the competent authority of his State of residence or nationality; the competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, and implement any agreement notwithstanding domestic time limits.
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: taxpayers may seek competent authority negotiation to prevent taxation contrary to the tax convention.
A mutual agreement procedure allows a person who believes actions by one or both Contracting States produce taxation inconsistent with the Convention to present the case to the competent authority of his State of residence or nationality; the competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, and implement any agreement notwithstanding domestic time limits.
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