Article 27 - Mutual Agreement Procedure

Mutual Agreement Procedure allows residents to seek competent authority negotiation to resolve taxation inconsistent with a tax convention.

Article 27 provides a Mutual Agreement Procedure whereby a resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention may present the case to the competent authority of his State of residence (or nationality as applicable) within the specified period. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to reach a mutual agreement with the other State's competent authority and may implement any agreement notwithstanding domestic time limits. Competent authorities shall also seek to resolve interpretation or application doubts, eliminate double taxation, improve information exchange under Article 28, communicate directly, and use a Commission for oral exchanges when advisable.