Mutual agreement procedure enables taxpayers to request competent authorities to resolve treaty taxation disputes and eliminate double taxation. Mutual agreement procedure allows a taxpayer who believes taxation under one or both Contracting States is not in accordance with the Convention to present the case to the competent authority of the State of residence; that authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, and any such agreement shall be implemented notwithstanding domestic time limits. Competent authorities shall also consult to resolve interpretative doubts, eliminate double taxation, communicate directly, and may exchange opinions through a Commission.
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 request competent authorities to resolve treaty taxation disputes and eliminate double taxation.
Mutual agreement procedure allows a taxpayer who believes taxation under one or both Contracting States is not in accordance with the Convention to present the case to the competent authority of the State of residence; that authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, and any such agreement shall be implemented notwithstanding domestic time limits. Competent authorities shall also consult to resolve interpretative doubts, eliminate double taxation, communicate directly, and may exchange opinions through a Commission.
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