Mutual Agreement Procedure lets taxpayers ask competent authorities to resolve treaty taxation mismatches and eliminate double taxation by cooperation. Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement to present the case to the competent authority of his residence or nationality within the applicable time limit. The competent authority shall endeavour, if the objection appears justified and it cannot itself solve the matter, to resolve the case by mutual agreement with the other Contracting State to avoid taxation inconsistent with the Agreement; such agreements are to be implemented notwithstanding domestic time limits. Competent authorities may directly communicate, including via a joint commission, to resolve interpretation or application issues and 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 lets taxpayers ask competent authorities to resolve treaty taxation mismatches and eliminate double taxation by cooperation.
Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement to present the case to the competent authority of his residence or nationality within the applicable time limit. The competent authority shall endeavour, if the objection appears justified and it cannot itself solve the matter, to resolve the case by mutual agreement with the other Contracting State to avoid taxation inconsistent with the Agreement; such agreements are to be implemented notwithstanding domestic time limits. Competent authorities may directly communicate, including via a joint commission, to resolve interpretation or application issues and to eliminate double taxation.
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