Mutual agreement procedure enables taxpayers to seek competent authority resolution of treaty taxation disputes and eliminate double taxation. The mutual agreement procedure allows a resident who believes treaty-inconsistent taxation will occur to present the case to the competent authority of the State of residence within the treaty's time limit; that authority must seek resolution by mutual agreement with the other State's competent authority and implement any agreement regardless of national time limits, while competent authorities may consult, communicate directly, and use a representative Commission to resolve interpretation, application, or double taxation issues.
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 taxpayers to seek competent authority resolution of treaty taxation disputes and eliminate double taxation.
The mutual agreement procedure allows a resident who believes treaty-inconsistent taxation will occur to present the case to the competent authority of the State of residence within the treaty's time limit; that authority must seek resolution by mutual agreement with the other State's competent authority and implement any agreement regardless of national time limits, while competent authorities may consult, communicate directly, and use a representative Commission to resolve interpretation, application, or double taxation issues.
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