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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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DT: Soviet Union: double taxation agreement, Article 22: Mutual agreement procedure for settling disputes

(1) Where a person to whom this Convention applies considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.
(2) The competent authority to whom the case is presented will endeavour, if the case appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the matter by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with the provisions of this Convention.
(3) The competent authorities of the Contracting States will endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Convention.