Mutual Agreement Procedure permits residents to seek competent-authority negotiation to resolve treaty-inconsistent taxation through bilateral cooperation. Mutual Agreement Procedure allows a resident who considers taxation inconsistent with the Convention to present a case to the competent authority of his State of residence within two years of assessment or withholding; the competent authority must endeavour to resolve justified objections alone or by mutual agreement with the other Contracting State, and competent authorities may consult, communicate directly, and use a Commission for oral exchanges to eliminate double taxation and resolve interpretive or application doubts.
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 permits residents to seek competent-authority negotiation to resolve treaty-inconsistent taxation through bilateral cooperation.
Mutual Agreement Procedure allows a resident who considers taxation inconsistent with the Convention to present a case to the competent authority of his State of residence within two years of assessment or withholding; the competent authority must endeavour to resolve justified objections alone or by mutual agreement with the other Contracting State, and competent authorities may consult, communicate directly, and use a Commission for oral exchanges to eliminate double taxation and resolve interpretive or application doubts.
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