Mutual agreement procedure enables residents to request competent authorities to resolve treaty taxation mismatches through binding bilateral agreement. A resident who believes treaty-inconsistent taxation will arise may present the case to his State's competent authority within three years of notice. If the competent authority deems the objection justified and cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to avoid treaty-inconsistent taxation, and any such agreement shall be implemented notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation not covered by the treaty, communicate directly, and use a Commission for oral exchanges when advisable.
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 request competent authorities to resolve treaty taxation mismatches through binding bilateral agreement.
A resident who believes treaty-inconsistent taxation will arise may present the case to his State's competent authority within three years of notice. If the competent authority deems the objection justified and cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to avoid treaty-inconsistent taxation, and any such agreement shall be implemented notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation not covered by the treaty, communicate directly, and use a Commission for oral exchanges when advisable.
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