Mutual agreement procedure enables taxpayers to seek competent authority negotiation to resolve treaty-related taxation discrepancies through bilateral consultation. The mutual agreement procedure permits 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 residence or nationality within the treaty's time limit; the competent authority shall, if justified and unresolved domestically, seek a mutual agreement with its counterpart to avoid such taxation and implement any agreement notwithstanding 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 enables taxpayers to seek competent authority negotiation to resolve treaty-related taxation discrepancies through bilateral consultation.
The mutual agreement procedure permits 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 residence or nationality within the treaty's time limit; the competent authority shall, if justified and unresolved domestically, seek a mutual agreement with its counterpart to avoid such taxation and implement any agreement notwithstanding domestic time limits.
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