Mutual Agreement Procedure enables competent authorities to resolve cross-border taxation conflicts by mutual agreement between treaty states. The Mutual Agreement Procedure permits a person to present to the competent authority of his residence (or nationality in specified cases) a claim that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement; the claim must be presented within three years of first notification. The competent authority should seek to resolve justified objections by mutual agreement with the other State's authority, implement any agreement notwithstanding domestic time limits, consult on interpretive difficulties, and may communicate directly or through a joint commission.
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 competent authorities to resolve cross-border taxation conflicts by mutual agreement between treaty states.
The Mutual Agreement Procedure permits a person to present to the competent authority of his residence (or nationality in specified cases) a claim that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement; the claim must be presented within three years of first notification. The competent authority should seek to resolve justified objections by mutual agreement with the other State's authority, implement any agreement notwithstanding domestic time limits, consult on interpretive difficulties, and may communicate directly or through a joint commission.
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