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Sayfa 713.2.Application of the Mutual Agreement Procedure
3.2.1.In General
The Mutual Agreement Procedure is included in Article 25 of both the OECD Model Agreement…
The Mutual Agreement Procedure, in its simplest terms, is a method of resolving disputes…
Requests for the Mutual Agreement Procedure can come from taxpayers or competent…
When individuals residing in one of the contracting states conclude that the actions…
According to the 2014 version of the OECD Model Agreement, two options are presented.…
However, in the 2017 revision of the OECD Model, changes were made to paragraph 1…
For this procedure, taxpayers can apply, and in cases where the provisions of the…
In paragraphs 1 and 2 of Article 25 of the OECD Model Agreement, it is stated that…
In the UN Model Agreement, the Mutual Agreement Procedure is structured as Alternative…
3.1.2.2.BEPS Action Plan 15: Multilateral Convention (MLI)
3.2.2.Application Procedure
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