Mutual agreement procedure under the Brazil tax convention enables cross-border tax disputes to be resolved through competent authority consultations. Mutual agreement procedure under the Brazil tax convention allows a resident to present a case to the competent authority where taxation not in accordance with the Convention arises, within three years of first notification. The competent authority must seek mutual agreement with the other Contracting State where the objection is justified and no internal solution is reached, and any agreement is implemented notwithstanding domestic limitation periods. The competent authorities may also resolve interpretative doubts, eliminate double taxation in uncovered cases, and communicate directly, including through a commission for oral exchange of views.
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 under the Brazil tax convention enables cross-border tax disputes to be resolved through competent authority consultations.
Mutual agreement procedure under the Brazil tax convention allows a resident to present a case to the competent authority where taxation not in accordance with the Convention arises, within three years of first notification. The competent authority must seek mutual agreement with the other Contracting State where the objection is justified and no internal solution is reached, and any agreement is implemented notwithstanding domestic limitation periods. The competent authorities may also resolve interpretative doubts, eliminate double taxation in uncovered cases, and communicate directly, including through a commission for oral exchange of views.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
AI OCR ✕
of 
TaxTMI 
TaxTMI 
