Mutual Agreement Procedure: competent authorities must seek resolution of treaty taxation disputes and eliminate double taxation. Mutual Agreement Procedure allows a taxpayer to present a case to the competent authority of his State of residence or nationality within three years of the first notification; the competent authority shall, if the objection appears justified and it cannot itself resolve the issue, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Agreement, and any such agreement must 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: competent authorities must seek resolution of treaty taxation disputes and eliminate double taxation.
Mutual Agreement Procedure allows a taxpayer to present a case to the competent authority of his State of residence or nationality within three years of the first notification; the competent authority shall, if the objection appears justified and it cannot itself resolve the issue, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Agreement, and any such agreement must be implemented notwithstanding domestic time limits.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
