Mutual agreement procedure enables residents to seek competent authority resolution of treaty-related taxation inconsistencies. A Mutual Agreement Procedure permits a resident to present a treaty inconsistency claim to the competent authority of the State of residence; that authority must seek resolution by mutual agreement with the other Contracting State's competent authority if the objection appears justified and cannot itself be resolved, and any agreement is to be implemented notwithstanding national time limits. Competent authorities shall endeavour to resolve interpretive or application difficulties, may communicate directly or by a joint Commission, and may set procedural requirements for residents to obtain treaty reliefs or exemptions.
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 residents to seek competent authority resolution of treaty-related taxation inconsistencies.
A Mutual Agreement Procedure permits a resident to present a treaty inconsistency claim to the competent authority of the State of residence; that authority must seek resolution by mutual agreement with the other Contracting State's competent authority if the objection appears justified and cannot itself be resolved, and any agreement is to be implemented notwithstanding national time limits. Competent authorities shall endeavour to resolve interpretive or application difficulties, may communicate directly or by a joint Commission, and may set procedural requirements for residents to obtain treaty reliefs or exemptions.
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