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Mutual Agreement Procedure enables taxpayers to request competent authorities to resolve treaty taxation disputes and eliminate double taxation. Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States lead to taxation contrary to the Agreement to present the case to the competent authority of residence or nationality within the prescribed time-limit; the competent authorities shall endeavour to resolve justified objections by mutual agreement to avoid taxation inconsistent with the Agreement and any agreement reached shall be implemented notwithstanding domestic time-limits. Competent authorities may consult, communicate directly, and convene a Commission to resolve interpretation issues and eliminate double taxation.
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 request competent authorities to resolve treaty taxation disputes and eliminate double taxation.
Mutual Agreement Procedure allows a person who considers that actions of one or both Contracting States lead to taxation contrary to the Agreement to present the case to the competent authority of residence or nationality within the prescribed time-limit; the competent authorities shall endeavour to resolve justified objections by mutual agreement to avoid taxation inconsistent with the Agreement and any agreement reached shall be implemented notwithstanding domestic time-limits. Competent authorities may consult, communicate directly, and convene a Commission to resolve interpretation issues and eliminate double taxation.
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