https://www.taxtmi.com/acts?id=6272 The Article provides a mutual agreement procedure permitting a resident to present a case to the competent authority within three years of the first notice if actions of one or both Contracting States cause taxation inconsistent with the Agreement; the competent authority must seek resolution by mutual agreement with the other State's competent authority and implement any agreement notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation beyond the Agreement's text, communicate directly, and may use a Commission for oral exchanges to reach agreement. en-us Sat, 19 Jan 2008 22:45:54 +0530 Tue, 08 Oct 2024 18:21:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/acts?id=6272 The Article provides a mutual agreement procedure permitting a resident to present a case to the competent authority within three years of the first notice if actions of one or both Contracting States cause taxation inconsistent with the Agreement; the competent authority must seek resolution by mutual agreement with the other State's competent authority and implement any agreement notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation beyond the Agreement's text, communicate directly, and may use a Commission for oral exchanges to reach agreement. Act-Rules DTAA Sat, 19 Jan 2008 22:45:54 +0530 https://www.taxtmi.com/acts?id=6272