Mutual agreement procedure allows taxpayers to seek competent authorities' resolution of treaty-based tax disputes through direct negotiation. Article 25 provides a Mutual Agreement Procedure allowing a person who believes actions by one or both Contracting States yield taxation not in accordance with the Convention to present the case to the competent authority of residence or nationality within a prescribed time limit. The competent authority shall, where it deems the objection justified and cannot itself arrive at a solution, seek a mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time limits, and may consult or convene a Commission to resolve interpretation, application, or double taxation issues.
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 allows taxpayers to seek competent authorities' resolution of treaty-based tax disputes through direct negotiation.
Article 25 provides a Mutual Agreement Procedure allowing a person who believes actions by one or both Contracting States yield taxation not in accordance with the Convention to present the case to the competent authority of residence or nationality within a prescribed time limit. The competent authority shall, where it deems the objection justified and cannot itself arrive at a solution, seek a mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time limits, and may consult or convene a Commission to resolve interpretation, application, or double taxation issues.
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