Mutual Agreement Procedure enables taxpayers to obtain treaty-based resolution of taxation conflicts through competent authority negotiation. The Mutual Agreement Procedure permits a taxpayer who believes actions of one or both Contracting States result in taxation not in accordance with the Convention to present the case to the competent authority of residence or nationality within three years of first notification; the competent authority shall, where justified and unable to resolve the matter alone, seek resolution by mutual agreement with the other Contracting State's competent authority, implement any agreement notwithstanding domestic time limits, endeavour to resolve interpretive difficulties, and may communicate directly to eliminate 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 taxpayers to obtain treaty-based resolution of taxation conflicts through competent authority negotiation.
The Mutual Agreement Procedure permits a taxpayer who believes actions of one or both Contracting States result in taxation not in accordance with the Convention to present the case to the competent authority of residence or nationality within three years of first notification; the competent authority shall, where justified and unable to resolve the matter alone, seek resolution by mutual agreement with the other Contracting State's competent authority, implement any agreement notwithstanding domestic time limits, endeavour to resolve interpretive difficulties, and may communicate directly to eliminate double taxation.
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