Mutual agreement procedure enables competent authorities to resolve treaty taxation disputes by mutual agreement to prevent inconsistent taxation. A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention may present the case to the competent authority within three years of first notification; the competent authority shall endeavour to resolve justified objections and, if necessary, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the Convention, implementing any agreement notwithstanding domestic time limits, and may communicate directly or form a Commission for oral exchanges to resolve interpretive or application difficulties.
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 by mutual agreement to prevent inconsistent taxation.
A person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention may present the case to the competent authority within three years of first notification; the competent authority shall endeavour to resolve justified objections and, if necessary, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the Convention, implementing any agreement notwithstanding domestic time limits, and may communicate directly or form a Commission for oral exchanges to resolve interpretive or application difficulties.
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