Mutual Agreement Procedure: competent authorities must resolve treaty taxation disputes by mutual agreement to avoid inconsistent taxation. A person believing that actions of one or both Contracting States result or will result in taxation inconsistent with the Agreement may present the case to the competent authority of his residence or nationality within the prescribed time limit. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid inconsistent taxation, and any agreement reached shall be implemented notwithstanding domestic limitation periods.
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: competent authorities must resolve treaty taxation disputes by mutual agreement to avoid inconsistent taxation.
A person believing that actions of one or both Contracting States result or will result in taxation inconsistent with the Agreement may present the case to the competent authority of his residence or nationality within the prescribed time limit. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid inconsistent taxation, and any agreement reached shall be implemented notwithstanding domestic limitation periods.
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