Mutual agreement procedure enables residents to seek competent authority negotiation to prevent treaty-inconsistent taxation. A resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of his State of residence within the prescribed time limit; the competent authority shall endeavour to resolve justified objections by mutual agreement with the other Contracting State's competent authority, implement any agreement notwithstanding domestic time limits, and consult or form a Commission to resolve interpretation issues or 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 prevent treaty-inconsistent taxation.
A resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of his State of residence within the prescribed time limit; the competent authority shall endeavour to resolve justified objections by mutual agreement with the other Contracting State's competent authority, implement any agreement notwithstanding domestic time limits, and consult or form a Commission to resolve interpretation issues or eliminate double taxation.
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