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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: taxpayers may present objections to competent authorities to resolve treaty taxation issues through bilateral agreement.</h1> Mutual agreement procedure allows a resident to present objections to the competent authority within the three year period when taxation appears inconsistent with the Agreement; the competent authority must, if justified and unable to resolve the issue domestically, seek a mutual agreement with the other State to avoid treaty-inconsistent taxation, implement any bilateral agreement notwithstanding domestic time limits, and may consult or form a Commission to resolve interpretation, application, or other double taxation issues.

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