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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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USA: Double taxation agreement, Exchange of Notes: Article 26

With reference to paragraph 2 of Article 26 (Mutual Agreement Procedure):

it is understood that where the competent authorities are endeavouring to resolve a case pursuant to the Article, neither Contracting State shall seek to collect the tax which is in dispute until the mutual agreement procedure has been completed. Any tax which is payable following the completion of the mutual agreement procedure shall, however, be subject to interest charges, and, if appropriate, surcharges or penalties, as long as it remains unpaid.

With reference to paragraph 3 of Article 26 (Mutual Agreement Procedure):

it is understood that any principle of general application established by an agreement between the competent authorities shall be published by both competent authorities.