Mutual Agreement Procedure enables residents to seek treaty-consistent resolution of cross-border tax disputes through competent authorities. The Mutual Agreement Procedure permits a resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement to present the case to the competent authority of his residence or nationality within the prescribed period. The competent authority shall endeavour to resolve justified objections by mutual agreement with the other Contracting State's competent authority, notwithstanding domestic time limits, and the competent authorities shall consult, communicate directly, and seek to eliminate double taxation and interpretive difficulties under the 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 enables residents to seek treaty-consistent resolution of cross-border tax disputes through competent authorities.
The Mutual Agreement Procedure permits a resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement to present the case to the competent authority of his residence or nationality within the prescribed period. The competent authority shall endeavour to resolve justified objections by mutual agreement with the other Contracting State's competent authority, notwithstanding domestic time limits, and the competent authorities shall consult, communicate directly, and seek to eliminate double taxation and interpretive difficulties under the Agreement.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.