Mutual agreement procedure allows taxpayers to seek competent-authority resolution and binding treaty implementation despite domestic time limits. Article 25 provides that a person who believes actions of one or both Contracting States result in taxation not in accordance with the Agreement may ... Summary
Mutual agreement procedure allows taxpayers to seek competent-authority resolution and binding treaty implementation despite domestic time limits.
Article 25 provides that a person who believes actions of one or both Contracting States result in taxation not in accordance with the Agreement may present the case to the competent authority of his State of residence or, where applicable, nationality. The competent authority shall, if the objection appears justified and it cannot itself reach a solution, endeavour to resolve the case by mutual agreement with the other Contracting State's competent authority and any agreement reached shall be implemented notwithstanding domestic time limits.
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