Mutual Agreement Procedure enables residents to seek competent authority negotiation to eliminate double taxation under the treaty. The Mutual Agreement Procedure permits a resident to present a claim to their competent authority where another territory's taxation action has resulted or will result in double taxation contrary to the Agreement; if deemed worthy of consideration, the competent authority must endeavour to reach an agreement with the other territory's competent authority to avoid double taxation.
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 negotiation to eliminate double taxation under the treaty.
The Mutual Agreement Procedure permits a resident to present a claim to their competent authority where another territory's taxation action has resulted or will result in double taxation contrary to the Agreement; if deemed worthy of consideration, the competent authority must endeavour to reach an agreement with the other territory's competent authority to avoid double taxation.
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