Mutual Agreement Procedure enables taxpayers to seek competent authority resolution to prevent taxation contrary to a tax treaty. A taxpayer may present a case to the competent authority of his residence or nationality if actions of one or both Contracting States result or will result in taxation not in accordance with the Convention; the claim must be presented within three years from first notification. The competent authorities shall endeavour to resolve justified objections by mutual agreement to avoid taxation inconsistent with the Convention and shall implement any agreement reached notwithstanding domestic time limits.
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 seek competent authority resolution to prevent taxation contrary to a tax treaty.
A taxpayer may present a case to the competent authority of his residence or nationality if actions of one or both Contracting States result or will result in taxation not in accordance with the Convention; the claim must be presented within three years from first notification. The competent authorities shall endeavour to resolve justified objections by mutual agreement to avoid taxation inconsistent with the Convention and shall implement any agreement reached notwithstanding domestic time limits.
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