Mutual Agreement Procedure enables taxpayers to request resolution of treaty taxation conflicts through competent authority negotiations. The Mutual Agreement Procedure allows a resident to present to its competent authority a claim that actions by one or both Contracting States produce taxation inconsistent with the Convention; the competent authority shall, if the objection appears justified and it cannot itself resolve the issue, seek a mutual agreement with the other State to avoid such taxation, implement any agreement notwithstanding domestic time limits, and endeavour to resolve interpretative or application difficulties, including by direct communication or oral exchange through a Commission of representatives.
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 request resolution of treaty taxation conflicts through competent authority negotiations.
The Mutual Agreement Procedure allows a resident to present to its competent authority a claim that actions by one or both Contracting States produce taxation inconsistent with the Convention; the competent authority shall, if the objection appears justified and it cannot itself resolve the issue, seek a mutual agreement with the other State to avoid such taxation, implement any agreement notwithstanding domestic time limits, and endeavour to resolve interpretative or application difficulties, including by direct communication or oral exchange through a Commission of representatives.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
