Mutual agreement procedure enables competent authorities to resolve and implement solutions for treaty-inconsistent taxation through direct negotiation. The provision establishes a mutual agreement procedure by which a resident may present alleged taxation contrary to the Convention to his State's competent authority within a specified period; that authority shall, if justified and unable to resolve the matter alone, seek mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time-limits, and consult or communicate directly (including by commission) to resolve interpretive doubts 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 competent authorities to resolve and implement solutions for treaty-inconsistent taxation through direct negotiation.
The provision establishes a mutual agreement procedure by which a resident may present alleged taxation contrary to the Convention to his State's competent authority within a specified period; that authority shall, if justified and unable to resolve the matter alone, seek mutual agreement with the other State's competent authority, implement any agreement notwithstanding domestic time-limits, and consult or communicate directly (including by commission) to resolve interpretive doubts and eliminate double taxation.
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