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Guide to mutual agreement procedures

Can a transfer pricing mutual agreement procedure be requested under a tax treaty when that tax treaty does not include an article equivalent to article 9.2 of the oecd 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.