Mutual agreement procedure enables residents to seek competent-authority negotiation to resolve taxation inconsistent with treaty provisions. The mutual agreement procedure allows a resident to present a case to the competent authority when actions by one or both Contracting States produce taxation inconsistent with the Convention; the competent authority will seek resolution by mutual agreement with the other State's authority, implement any agreement regardless of domestic time limits, and the competent authorities may directly communicate or form a Commission to resolve interpretation issues and eliminate double taxation.
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 seek competent-authority negotiation to resolve taxation inconsistent with treaty provisions.
The mutual agreement procedure allows a resident to present a case to the competent authority when actions by one or both Contracting States produce taxation inconsistent with the Convention; the competent authority will seek resolution by mutual agreement with the other State's authority, implement any agreement regardless of domestic time limits, and the competent authorities may directly communicate or form a Commission to resolve interpretation issues and eliminate double taxation.
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