4.37 Anyone wishing to apply this mutual agreement procedure must apply to the competent authority of his country of residence within three years of the first notification of transfer pricing adjustment. This procedure operates independently and in addition to the national remedies available to taxpayers. [Article 8, paragraph 1] 2.373 In some cases, the competent authorities do not agree on a solution for a particular case. Paragraph 6 of this section provides for the use of an arbitration procedure to resolve these cases. The provisions of this paragraph are largely consistent with the provisions of Article 25, paragraph 5 (mutual agreement procedure) of the OECD model. 5.4 Tax treaties reduce or eliminate double taxation by providing, in certain situations, to limit tax duties to different types of income. The countries concerned also agree on methods of reducing double taxation when both countries use their right to tax. In the absence of provisions to reduce the resulting double taxation, international trade would be seriously hampered. The text of the new double taxation agreement is available at www.taxpolicy.ird.govt.nz 2,314 Australian general rules on compensatory taxation of foreign income, as well as in the provisions of this article and the Convention in general, which will serve as the basis for the Australian scheme to exempt an Australian resident from the double taxation of income, profits or profits also taxed in New Zealand.
The Jersey Agreement will promote a closer bilateral relationship between Australia and Australia by removing the double taxation of certain individuals` incomes, including pension recipients, civil servants, students and apprentices. 2.260 If the application of this section were to lead to the taxation of income or profit in both states, the country in which the person who deducts the income or profit is resident (in accordance with Article 4 (residents) is required, under section 23 (elimination of double taxation), to grant a double tax reduction for the tax collected by the other country. 5.99 No significant additional costs have been identified for the subjects who should result from the agreement Jersey. The agreement should simplify the tax obligations of countries that fall within its scope. 2.312 However, it is necessary to impose a method of double taxation relief for other categories of income, profits or profits that will continue to be taxed in both countries under the Convention.