Mutual agreement procedure allows taxpayers to seek competent authority negotiation to correct treaty-based taxation inconsistencies. Resident entitlement to invoke the mutual agreement procedure exists when actions of one or both Contracting States result or will result in taxation not in accordance with the Convention; the resident may submit the case to the competent authority of his State of residence within three years of notice. The competent authority, if it finds the objection justified and cannot resolve it alone, shall endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, and any such agreement shall be implemented 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 allows taxpayers to seek competent authority negotiation to correct treaty-based taxation inconsistencies.
Resident entitlement to invoke the mutual agreement procedure exists when actions of one or both Contracting States result or will result in taxation not in accordance with the Convention; the resident may submit the case to the competent authority of his State of residence within three years of notice. The competent authority, if it finds the objection justified and cannot resolve it alone, shall endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, and any such agreement shall be implemented notwithstanding domestic time limits.
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