Australian Tax Treaties
Slovak Agreement
AGREEMENT BETWEEN AUSTRALIA AND THE SLOVAK REPUBLIC FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME
ARTICLE 24
Mutual Agreement Procedure
1.
Where a person who is a resident of a Contracting State considers that the actions of the competent authority of a Contracting State result or will result for the person in taxation not in accordance with the provisions of this Agreement, the person may, notwithstanding the remedies provided by the national laws of the Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident. The case must be presented within four years from the first notification of the action giving rise to taxation not in accordance with the provisions of this Agreement.
2.
The competent authority shall endeavour, if the claim appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve the case 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 Agreement. The solution so reached shall be implemented notwithstanding any time limits in the national laws of the Contracting States.
3.
The competent authorities of the Contracting States shall jointly endeavour to resolve any difficulties or doubts arising as to the application of this Agreement.
4.
The competent authorities of the Contracting States may communicate with each other directly for the purpose of giving effect to the provisions of this Agreement.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
Where a person who is a resident of a Contracting State considers that the actions of the competent authority of a Contracting State result or will result for the person in taxation not in accordance with the provisions of this Agreement, the person may, notwithstanding the remedies provided by the national laws of the Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident. The case must be presented within four years from the first notification of the action giving rise to taxation not in accordance with the provisions of this Agreement.
2.
The competent authority shall endeavour, if the claim appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve the case 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 Agreement. The solution so reached shall be implemented notwithstanding any time limits in the national laws of the Contracting States.
3.
The competent authorities of the Contracting States shall jointly endeavour to resolve any difficulties or doubts arising as to the application of this Agreement.
4.
The competent authorities of the Contracting States may communicate with each other directly for the purpose of giving effect to the provisions of this Agreement.
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