Mutual agreement procedure enables residents to request competent authority intervention to resolve treaty taxation inconsistencies by mutual agreement. A resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present a written case to the competent authority of his state of residence within the prescribed period; that authority shall, if the objection appears justified and it cannot itself reach a satisfactory solution, endeavour to resolve the case by mutual agreement with the competent authority of the other Contracting State to avoid taxation not in accordance with the Agreement, and competent authorities shall endeavour to resolve interpretation or application doubts and consult to eliminate double taxation in cases not provided for in the Agreement.
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 enables residents to request competent authority intervention to resolve treaty taxation inconsistencies by mutual agreement.
A resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present a written case to the competent authority of his state of residence within the prescribed period; that authority shall, if the objection appears justified and it cannot itself reach a satisfactory solution, endeavour to resolve the case by mutual agreement with the competent authority of the other Contracting State to avoid taxation not in accordance with the Agreement, and competent authorities shall endeavour to resolve interpretation or application doubts and consult to eliminate double taxation in cases not provided for in the Agreement.
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