Mutual Agreement Procedure enables taxpayers to seek bilateral resolution of treaty-related taxation disputes through competent authorities. A Mutual Agreement Procedure allows a person who believes taxation by one or both Contracting States is inconsistent with the Agreement to present the case to the competent authority of his residence or nationality within the specified time limit; the competent authority must, if justified and unable to resolve the matter domestically, seek a mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time limits, and consult or form a Commission to resolve interpretation, application, or unprovided 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 enables taxpayers to seek bilateral resolution of treaty-related taxation disputes through competent authorities.
A Mutual Agreement Procedure allows a person who believes taxation by one or both Contracting States is inconsistent with the Agreement to present the case to the competent authority of his residence or nationality within the specified time limit; the competent authority must, if justified and unable to resolve the matter domestically, seek a mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time limits, and consult or form a Commission to resolve interpretation, application, or unprovided double taxation issues.
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