Mutual Agreement Procedure allows residents to seek competent authority negotiation to prevent taxation inconsistent with a tax treaty. Article 26 provides a Mutual Agreement Procedure allowing a resident to present a case to the competent authority within three years if taxation is or ... Summary
Mutual Agreement Procedure allows residents to seek competent authority negotiation to prevent taxation inconsistent with a tax treaty.
Article 26 provides a Mutual Agreement Procedure allowing a resident to present a case to the competent authority within three years if taxation is or will be inconsistent with the DTAA; the competent authority shall seek mutual agreement with the other Contracting State to avoid such taxation, implement any agreement despite domestic time limits, endeavour to resolve interpretation or application issues and may communicate directly or form a Commission for oral exchanges.
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