Mutual agreement procedure enables taxpayers to seek competent authority negotiation to prevent taxation contrary to a tax convention. Mutual agreement procedure allows a person who considers that actions of one or both Contracting States will result in taxation not in accordance with the Convention to present the case to the competent authority of his residence or nationality within the Convention's time limit; the competent authority shall endeavour, if the objection appears justified and it cannot itself reach a satisfactory solution, to resolve the case by mutual agreement with the other State's competent authority, and any agreement reached shall be implemented notwithstanding domestic time limits.
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 taxpayers to seek competent authority negotiation to prevent taxation contrary to a tax convention.
Mutual agreement procedure allows a person who considers that actions of one or both Contracting States will result in taxation not in accordance with the Convention to present the case to the competent authority of his residence or nationality within the Convention's time limit; the competent authority shall endeavour, if the objection appears justified and it cannot itself reach a satisfactory solution, to resolve the case by mutual agreement with the other State's competent authority, and any agreement reached shall be implemented notwithstanding domestic time limits.
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