Mutual Agreement Procedure enables residents to seek treaty-consistent relief through competent authorities and mutual agreement between States. A resident who considers that taxation is not in accordance with the Agreement may present a written case to the competent authority of the State of residence; under the MLI replacement the case must be presented within three years from first notification of the action. The competent authority shall endeavour to resolve justified objections and, if necessary, reach a mutual agreement with the other Contracting State to avoid taxation not in accordance with the Agreement, and competent authorities shall consult to resolve interpretation doubts 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 residents to seek treaty-consistent relief through competent authorities and mutual agreement between States.
A resident who considers that taxation is not in accordance with the Agreement may present a written case to the competent authority of the State of residence; under the MLI replacement the case must be presented within three years from first notification of the action. The competent authority shall endeavour to resolve justified objections and, if necessary, reach a mutual agreement with the other Contracting State to avoid taxation not in accordance with the Agreement, and competent authorities shall consult to resolve interpretation doubts and eliminate double taxation.
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