Mutual Agreement Procedure

1. Introduction

This Agreement is entered into by and between the Parties hereto for the mutual purpose of providing a procedure to resolve disputes concerning the interpretation and application of tax treaties or similar agreements. The objective is to eliminate double taxation and foster cooperation between the parties.

2. Definitions

For the purposes of this Agreement, the following terms shall have the meanings set forth below:

• Competent Authorities: The official bodies responsible for administering tax matters within their respective jurisdictions.

• Double Taxation: The imposition of comparable taxes in two or more jurisdictions on the same income or asset.

• Parties: The signatories to this Agreement, typically represented by their respective Competent Authorities.

3. Scope of Agreement

This Agreement applies to disputes arising under tax treaties between the Parties, specifically concerning the interpretation, application, or both, of such treaties. The Agreement aims to ensure that such disputes are resolved in a fair manner.

4. Procedure

4.1 Initiation

Either Party may initiate the Mutual Agreement Procedure by notifying the other Party in writing of its intention to seek resolution under this Agreement. The notification must include a description of the issue in dispute and relevant treaty provisions.

4.2 Consultations

Upon receipt of the notification, the Competent Authorities shall, without undue delay, communicate with each other to discuss and attempt to resolve the dispute through consultations and exchange of pertinent information.

4.3 Resolution Timeline

The Competent Authorities shall exert every effort to resolve the dispute within a period of 24 months from the initiation of the Mutual Agreement Procedure.

4.4 Agreement

Any agreement reached by the Competent Authorities shall be in writing and shall specify the manner in which the dispute will be resolved in accordance with the applicable tax treaties.

4.5 Implementation

The Parties agree to implement any resolutions reached through the Mutual Agreement Procedure in a timely and effective manner, consistent with their respective domestic laws.

5. Confidentiality

Any information exchanged pursuant to this Agreement is to be treated as confidential and shall not be disclosed to any unauthorized parties, except as required by law or with the consent of the Parties.

6. Termination

This Agreement may be terminated by mutual consent of the Parties upon written notice. The obligations related to confidentiality shall survive the termination of this Agreement.

7. Governing Law and Dispute Resolution

This Agreement shall be governed by the principles of international law applicable to treaties. Any disputes arising under this Agreement that cannot be resolved through the provided procedure shall be settled through arbitration.

Signatures

IN WITNESS WHEREOF, the Parties hereto have executed this Mutual Agreement Procedure Agreement as of the date specified below.

[Your Name]

Ena Cassin

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