Mutual Agreement Procedure allows taxpayers to seek relief from treaty-inconsistent taxation by presenting cases to competent authorities. A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of the State of residence or, where applicable, of nationality within three years of first notification. The competent authority shall endeavour to resolve justified objections and, if necessary, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the Agreement, and any such agreement shall be implemented notwithstanding domestic 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 allows taxpayers to seek relief from treaty-inconsistent taxation by presenting cases to competent authorities.
A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of the State of residence or, where applicable, of nationality within three years of first notification. The competent authority shall endeavour to resolve justified objections and, if necessary, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the Agreement, and any such agreement shall be implemented notwithstanding domestic time limits.
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