Mutual Agreement Procedure allows residents to seek competent authority negotiation to resolve treaty tax mismatches through direct talks. Residents may present cases to their competent authority when taxation appears inconsistent with the Convention; the competent authority shall endeavour, if justified and unable to resolve the matter itself, to reach a mutual agreement with the other State's competent authority to avoid taxation contrary to the Convention. Competent authorities must also attempt to resolve interpretation or application difficulties, consult to eliminate double taxation beyond the Convention's express terms, communicate directly, and may convene a commission for oral exchanges to reach agreement.
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 allows residents to seek competent authority negotiation to resolve treaty tax mismatches through direct talks.
Residents may present cases to their competent authority when taxation appears inconsistent with the Convention; the competent authority shall endeavour, if justified and unable to resolve the matter itself, to reach a mutual agreement with the other State's competent authority to avoid taxation contrary to the Convention. Competent authorities must also attempt to resolve interpretation or application difficulties, consult to eliminate double taxation beyond the Convention's express terms, communicate directly, and may convene a commission for oral exchanges to reach agreement.
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