Mutual Agreement Procedure ensures bilateral competent authority negotiations to resolve treaty-inconsistent taxation and binding implementation. A Mutual Agreement Procedure allows a person alleging treaty-inconsistent taxation to present the case to the competent authority of residence or nationality within three years; the competent authority shall, if justified and unable to resolve the issue alone, negotiate bilaterally to avoid taxation contrary to the convention, implement any agreement notwithstanding domestic time-limits, resolve interpretive or application difficulties, and may communicate directly or convene a Commission to facilitate agreement.
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 ensures bilateral competent authority negotiations to resolve treaty-inconsistent taxation and binding implementation.
A Mutual Agreement Procedure allows a person alleging treaty-inconsistent taxation to present the case to the competent authority of residence or nationality within three years; the competent authority shall, if justified and unable to resolve the issue alone, negotiate bilaterally to avoid taxation contrary to the convention, implement any agreement notwithstanding domestic time-limits, resolve interpretive or application difficulties, and may communicate directly or convene a Commission to facilitate agreement.
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