Mutual agreement procedure lets a resident seek competent authorities' negotiation to remedy taxation contrary to the treaty. Mutual agreement procedure enables a resident who considers that actions by one or both Contracting States result in taxation not in accordance with the Convention to present the case to the competent authority; that authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to settle by mutual agreement with the other competent authority to avoid treaty-inconsistent taxation, and any agreement reached shall be implemented notwithstanding national 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 lets a resident seek competent authorities' negotiation to remedy taxation contrary to the treaty.
Mutual agreement procedure enables a resident who considers that actions by one or both Contracting States result in taxation not in accordance with the Convention to present the case to the competent authority; that authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to settle by mutual agreement with the other competent authority to avoid treaty-inconsistent taxation, and any agreement reached shall be implemented notwithstanding national time-limits.
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