Mutual Agreement Procedure enables taxpayers to seek competent authority negotiations when taxation conflicts with the tax treaty. A taxpayer may present a case to the competent authority of his residence or nationality within three years of the first notification if actions lead to taxation not in accordance with the Convention. The competent authority shall, if the objection appears justified and it cannot itself secure a satisfactory solution, endeavour to resolve the case by mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Convention; such agreements are to be implemented notwithstanding domestic time limits. Competent authorities may directly communicate, consult to eliminate double taxation, and convene a joint Commission for oral exchanges.
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 taxpayers to seek competent authority negotiations when taxation conflicts with the tax treaty.
A taxpayer may present a case to the competent authority of his residence or nationality within three years of the first notification if actions lead to taxation not in accordance with the Convention. The competent authority shall, if the objection appears justified and it cannot itself secure a satisfactory solution, endeavour to resolve the case by mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Convention; such agreements are to be implemented notwithstanding domestic time limits. Competent authorities may directly communicate, consult to eliminate double taxation, and convene a joint Commission for oral exchanges.
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