Mutual Agreement Procedure enables competent authorities to resolve treaty-based double taxation disputes and secure consistent tax application. A person claiming taxation contrary to the Agreement may present the case to the competent authority of residence or nationality within three years of the first notification. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Agreement, and any agreement reached shall be implemented notwithstanding domestic time limits. Competent authorities shall endeavour to resolve interpretation or application issues, may consult to eliminate double taxation beyond the Agreement, determine modes of applying exemptions or reductions by mutual agreement, and communicate directly to reach such agreements.
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Mutual Agreement Procedure enables competent authorities to resolve treaty-based double taxation disputes and secure consistent tax application.
A person claiming taxation contrary to the Agreement may present the case to the competent authority of residence or nationality within three years of the first notification. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Agreement, and any agreement reached shall be implemented notwithstanding domestic time limits. Competent authorities shall endeavour to resolve interpretation or application issues, may consult to eliminate double taxation beyond the Agreement, determine modes of applying exemptions or reductions by mutual agreement, and communicate directly to reach such agreements.
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