Mutual Agreement Procedure: competent authorities negotiate to resolve taxation inconsistent with the treaty and eliminate double taxation. Mutual Agreement Procedure allows a person asserting taxation contrary to the Convention to present a case to the competent authority of residence or nationality; that authority shall, if the objection appears justified and it cannot itself reach a solution, seek a mutual agreement with the other Contracting State's competent authority to avoid treaty-inconsistent taxation, implement any agreement notwithstanding domestic time-limits, and consult or communicate directly to resolve interpretation, application, or double taxation issues.
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: competent authorities negotiate to resolve taxation inconsistent with the treaty and eliminate double taxation.
Mutual Agreement Procedure allows a person asserting taxation contrary to the Convention to present a case to the competent authority of residence or nationality; that authority shall, if the objection appears justified and it cannot itself reach a solution, seek a mutual agreement with the other Contracting State's competent authority to avoid treaty-inconsistent taxation, implement any agreement notwithstanding domestic time-limits, and consult or communicate directly to resolve interpretation, application, or double taxation issues.
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