Mutual agreement procedure enables competent authorities to resolve treaty taxation disputes and avoid taxation contrary to the treaty. The Mutual Agreement Procedure permits a resident to present to the competent authority a case that actions by one or both Contracting States cause taxation contrary to the Agreement; the authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid such taxation, implement any agreement notwithstanding domestic time limits, consult to resolve interpretation or application difficulties, eliminate double taxation where not provided for, communicate directly, and, if advisable, hold oral exchanges via a commission of representatives.
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 treaty taxation disputes and avoid taxation contrary to the treaty.
The Mutual Agreement Procedure permits a resident to present to the competent authority a case that actions by one or both Contracting States cause taxation contrary to the Agreement; the authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid such taxation, implement any agreement notwithstanding domestic time limits, consult to resolve interpretation or application difficulties, eliminate double taxation where not provided for, communicate directly, and, if advisable, hold oral exchanges via a commission of representatives.
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