Mutual agreement procedure enables residents to seek treaty-based resolution of taxation inconsistent with the tax convention. The Mutual Agreement Procedure allows a resident 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 his residence within three years of the first notice. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Convention, implement any agreement notwithstanding national time limits, and communicate directly to resolve interpretation 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 residents to seek treaty-based resolution of taxation inconsistent with the tax convention.
The Mutual Agreement Procedure allows a resident 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 his residence within three years of the first notice. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Convention, implement any agreement notwithstanding national time limits, and communicate directly to resolve interpretation or application difficulties.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
TaxTMI 
