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          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.

          <h1>Mutual Agreement Procedure enables taxpayers to ask competent authorities to resolve treaty taxation disputes through mutual agreement.</h1> The Mutual Agreement Procedure permits a person who believes actions of one or both Contracting States result in taxation inconsistent with the DTAA to present the case to the competent authority of residence or nationality within the prescribed time limit; the competent authority shall, if justified and unable to resolve the matter domestically, seek a mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time limits, and consult or communicate directly (including via a Commission) to resolve interpretation or application issues and eliminate double taxation.

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