What kind of dispute resolution is addressed under Article pertaining to Mutual Agreement Procedure? Give any two key differences between OECD Model…

Where a taxpayer believes that the treatment accorded by either or both Contracting States (CSs) is not in accordance with the provisions of the tax treaty, this Article provides for dispute resolution through bilateral negotiations between competent authorities (CAS) of both CSs. OECD MC UN MC Request for MAP The taxpayer may make a request to either CS Alternative A - Taxpayer has to approach Resident State (RS) or the country of his nationality. Alternative B - Reference to an arbitration process as part of MAP. The decision arrived at through the process is binding unless a person directly affected does not accept it. Time limit Stipulates a time limit of 2 years from the date when all the information required by the CAS in order to address the case need to be provided to both CAS. An arbitration may be initiated if the competent authorities (CAS) are unable to reach an agreement on a case within 3 years from presentation of that case [Alternative B] Who can request Arbitration? Arbitration must be for requested in writing by the person who initiated the case Arbitration must be requested by the CAS of one of the CS. Once such a request is made, the taxpayer will be notified [Alternative B] Departure from arbitration by CAS No specific provision departure from arbitration. The CAS may depart from for the arbitration decision if they agree to do so within 6 months after the decision has been communicated to them [Alternative B] Note: Any of the two differences above can be stated.