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Guide to mutual agreement procedures

Can a mutual agreement procedure relating to transfer pricing be requested under a tax agreement when that convention does not include an article equivalent to Article 9.2 of the OECD's model tax convention on income and on capital?

Even if an applicable Tax Treaty with a mutual agreement procedure provision does not contain an article equivalent to Article 9.2 of the OECD Model Tax Convention on Income and on Capital, the initiation of a mutual agreement procedure relating to transfer pricing will be allowed if the necessary requirements are satisfied.