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Onal Tax Directorate ("Director General"), Canada Customs and Revenue Agency (CCRA), Competent Authority for Canada and the Director - International ("Director - International"), Large & MidSize Business (LMSB), Internal Revenue Service (IRS), Competent Authority for the United States announced today a number of developments designed to implement the Memorandum of Understanding (MOU), which was executed on June 3, 2005. These developments are as follows. Appointment of Representatives. The Direc.
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Mou FAQ
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Under US tax treaties, taxpayers can request the competent authority to enter discussions with other contracting states in respect of transfer pricing issues. The competent authority is a government agency responsible for interpreting and enforcing tax treaties.
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It means that in ance with the tax treaty, certain designations are made as to who is considered competent authority. For example, when it comes to the United States — the “Secretary of Treasury or his delegate” is considered to be the competent authority.
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The Multilateral Competent Authority Agreement (“the MCAA”) is a multilateral framework agreement that provides a standardised and efficient mechanism to facilitate the automatic exchange of information in ance with the Standard for Automatic Exchange of Financial Information in Tax Matters (“the Standard”).
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The accelerated competent authority procedure (ACAP) complements the standard MAP process by providing an efficient mechanism to extend an agreed resolution to subsequent filed years.
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The Multilateral Competent Authority Agreement (“the MCAA”) is a multilateral framework agreement that provides a standardised and efficient mechanism to facilitate the automatic exchange of information in ance with the Standard for Automatic Exchange of Financial Information in Tax Matters (“the Standard”).
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It means that in ance with the tax treaty, certain designations are made as to who is considered competent authority. For example, when it comes to the United States — the “Secretary of Treasury or his delegate” is considered to be the competent authority.
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A Competent Authority Arrangement is a bilateral agreement between the United States and the treaty partner to clarify or interpret treaty provisions.
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A competent authority is any person or organization that has the legally delegated or invested authority, capacity, or power to perform a designated function. Similarly, once an authority is delegated to perform a certain act, only the competent authority is entitled to take accounts therefrom and no one else.
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