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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
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DT: Cyprus: double taxation agreement, Article 27: Mutual agreement procedure

(1) Where a resident of one of the Contracting States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the taxation laws in force in the Contracting States, present his case to the competent authority of the Contracting State of which he is a resident.

(2) The competent authority of the first-mentioned Contracting State shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve that case by mutual agreement with the competent authority of the other Contracting State with a view to the avoidance of taxation which is not in accordance with this Convention.

(3) The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Convention.

(4) The competent authorities of the Contracting States may communicate with each other directly for the purposes of giving effect to the provisions of this Convention.