Mutual Agreement Procedure: competent authorities must resolve treaty taxation disputes and eliminate double taxation through direct consultation. The Mutual Agreement Procedure allows a person who believes actions of one or both Contracting States will cause taxation not in accordance with the Convention to present the case to the competent authority of his residence or nationality within three years of first notification; the competent authority will seek a mutual agreement with the other State's competent authority to avoid such taxation and implement any agreement 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 resolve treaty taxation disputes and eliminate double taxation through direct consultation.
The Mutual Agreement Procedure allows a person who believes actions of one or both Contracting States will cause taxation not in accordance with the Convention to present the case to the competent authority of his residence or nationality within three years of first notification; the competent authority will seek a mutual agreement with the other State's competent authority to avoid such taxation and implement any agreement notwithstanding domestic time limits.
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