Mutual Agreement Procedure enables competent authorities to eliminate taxation contrary to the treaty through direct negotiation and agreement. Where a person contends that actions by one or both Contracting States result or will result in taxation not in accordance with the Convention, they may present the case to the competent authority of their State of residence or, if applicable, of their State of nationality within the prescribed time limit from first notification. If the competent authority finds the objection justified but cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to eliminate taxation inconsistent with the Convention; competent authorities shall endeavour to resolve interpretive or application difficulties and may communicate directly to reach and implement such agreements.
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Provisions expressly mentioned in the judgment/order text.
Mutual Agreement Procedure enables competent authorities to eliminate taxation contrary to the treaty through direct negotiation and agreement.
Where a person contends that actions by one or both Contracting States result or will result in taxation not in accordance with the Convention, they may present the case to the competent authority of their State of residence or, if applicable, of their State of nationality within the prescribed time limit from first notification. If the competent authority finds the objection justified but cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to eliminate taxation inconsistent with the Convention; competent authorities shall endeavour to resolve interpretive or application difficulties and may communicate directly to reach and implement such agreements.
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