Mutual agreement procedure enables competent authority negotiations to resolve treaty-related taxation and interpretation disputes. A resident may present a case to the competent authority alleging taxation inconsistent with the treaty; the authority shall, if the objection appears justified and it cannot itself resolve the issue, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the treaty, and implement any agreement notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretative or application difficulties, consult to eliminate double taxation beyond treaty provisions, communicate directly, and use a commission for oral exchanges when advisable.
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 authority negotiations to resolve treaty-related taxation and interpretation disputes.
A resident may present a case to the competent authority alleging taxation inconsistent with the treaty; the authority shall, if the objection appears justified and it cannot itself resolve the issue, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the treaty, and implement any agreement notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretative or application difficulties, consult to eliminate double taxation beyond treaty provisions, communicate directly, and use a commission for oral exchanges when advisable.
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