Mutual agreement procedure allows residents to invoke competent authority negotiations to resolve treaty-based double taxation disputes. A resident believing taxation by one or both Contracting States is not in accordance with the Convention may present the case to his State's competent authority, which shall, if the objection seems justified and it cannot itself resolve the matter, seek mutual agreement with the other State's competent authority to avoid such taxation. The competent authorities shall endeavour to resolve interpretive or application difficulties and may consult or communicate directly, including by oral exchanges through representatives, to eliminate double taxation, even in cases not expressly provided for in the Convention.
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 allows residents to invoke competent authority negotiations to resolve treaty-based double taxation disputes.
A resident believing taxation by one or both Contracting States is not in accordance with the Convention may present the case to his State's competent authority, which shall, if the objection seems justified and it cannot itself resolve the matter, seek mutual agreement with the other State's competent authority to avoid such taxation. The competent authorities shall endeavour to resolve interpretive or application difficulties and may consult or communicate directly, including by oral exchanges through representatives, to eliminate double taxation, even in cases not expressly provided for in the Convention.
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