Mutual Agreement Procedure allows taxpayers to seek competent-authority resolution of treaty taxation conflicts, enabling binding mutual agreements. A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of his State of residence or nationality within the prescribed time limit; the competent authority shall endeavour to resolve justified objections and, if necessary, reach a mutual agreement with the other Contracting State to avoid taxation contrary to the Agreement, implementable notwithstanding domestic time limits, and competent authorities may consult, resolve interpretation doubts, and communicate directly to eliminate double taxation.
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-authority resolution of treaty taxation conflicts, enabling binding mutual agreements.
A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of his State of residence or nationality within the prescribed time limit; the competent authority shall endeavour to resolve justified objections and, if necessary, reach a mutual agreement with the other Contracting State to avoid taxation contrary to the Agreement, implementable notwithstanding domestic time limits, and competent authorities may consult, resolve interpretation doubts, and communicate directly to eliminate double taxation.
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