Mutual agreement procedure enables competent authorities to resolve tax inconsistencies and eliminate double taxation through direct consultation. Mutual agreement procedure allows a person alleging taxation inconsistent with the Agreement to present the case to the competent authority of his State of residence or nationality within the specified time limit. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the Agreement, and implement any agreement notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretation or application difficulties, may consult to eliminate double taxation not covered by the Agreement, and may communicate directly or by commission to reach agreement.
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Provisions expressly mentioned in the judgment/order text.
Mutual agreement procedure enables competent authorities to resolve tax inconsistencies and eliminate double taxation through direct consultation.
Mutual agreement procedure allows a person alleging taxation inconsistent with the Agreement to present the case to the competent authority of his State of residence or nationality within the specified time limit. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the Agreement, and implement any agreement notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretation or application difficulties, may consult to eliminate double taxation not covered by the Agreement, and may communicate directly or by commission to reach agreement.
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