Mutual agreement procedure lets taxpayers seek bilateral resolution of treaty taxation disputes via competent authorities and agreement. Mutual agreement procedure allows a person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention to present the case to the competent authority of the State of residence or nationality within the Convention's time limit. The competent authority shall seek to resolve justified objections by mutual agreement with the other State's competent authority and endeavour to resolve interpretation or application difficulties, consult to eliminate double taxation, communicate directly, and, if needed, exchange views through a Commission; agreed solutions are implemented despite domestic time limits.
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 lets taxpayers seek bilateral resolution of treaty taxation disputes via competent authorities and agreement.
Mutual agreement procedure allows a person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention to present the case to the competent authority of the State of residence or nationality within the Convention's time limit. The competent authority shall seek to resolve justified objections by mutual agreement with the other State's competent authority and endeavour to resolve interpretation or application difficulties, consult to eliminate double taxation, communicate directly, and, if needed, exchange views through a Commission; agreed solutions are implemented despite domestic time limits.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
