Mutual Agreement Procedure enables taxpayers to seek competent authority negotiations to resolve cross border taxation inconsistent with a tax convention. A taxpayer may present to the competent authority of residence (or nationality where applicable) an objection to actions causing taxation inconsistent with the convention within a three-year period; the competent authority must endeavour to resolve justified objections and, if unable, seek mutual agreement with the other Contracting State to eliminate improper taxation, implementing any agreement notwithstanding domestic time-limits. Competent authorities should also resolve interpretive or application difficulties and may communicate directly, including via a joint commission, to 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 taxpayers to seek competent authority negotiations to resolve cross border taxation inconsistent with a tax convention.
A taxpayer may present to the competent authority of residence (or nationality where applicable) an objection to actions causing taxation inconsistent with the convention within a three-year period; the competent authority must endeavour to resolve justified objections and, if unable, seek mutual agreement with the other Contracting State to eliminate improper taxation, implementing any agreement notwithstanding domestic time-limits. Competent authorities should also resolve interpretive or application difficulties and may communicate directly, including via a joint commission, to eliminate double taxation.
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