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          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.

          <h1>Mutual agreement procedure lets residents seek competent authority resolution of treaty-inconsistent taxation within prescribed time.</h1> A resident may submit to his competent authority, within three years from assessment or withholding, a case alleging taxation not in accordance with the Convention. If justified and unresolved domestically, the competent authorities shall endeavour to settle the case by mutual agreement to avoid treaty-inconsistent taxation, implement any agreement notwithstanding national time limits, resolve interpretive difficulties, and may communicate directly or convene a commission of representatives to reach agreement.

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