Mutual Agreement Procedure enables residents to ask competent authorities to secure bilateral relief where taxation conflicts with the tax treaty. Mutual Agreement Procedure allows a resident to present a case to their competent authority if treaty-inconsistent taxation is alleged; the competent 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 taxation not in accordance with the Convention, and competent authorities may directly communicate to resolve interpretation or application doubts.
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 residents to ask competent authorities to secure bilateral relief where taxation conflicts with the tax treaty.
Mutual Agreement Procedure allows a resident to present a case to their competent authority if treaty-inconsistent taxation is alleged; the competent 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 taxation not in accordance with the Convention, and competent authorities may directly communicate to resolve interpretation or application doubts.
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