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Income Tax Act, 1962 (Act No. 58 of 1962)


2022 Notices


African Tax Administration Forum Agreement on Mutual Assistance in Tax Matters

Article 12 : Mutual Agreement Procedure


1. Where difficulties or doubts arise between two or more Contracting Parties regarding the implementation or interpretation of this Agreement, the Competent Authorities of those Contracting Parties shall endeavour to resolve the matter by mutual agreement.


2. In addition to the agreements referred to in paragraph 1, the Competent Authorities of two or more Contracting Parties may mutually agree:
(a) on the procedures to be used under Articles 4, 5, 6 and 7;
(b) on the language to be used in making and responding to requests in accordance with the Agreement.


3. The Competent Authorities of the Contracting Parties may communicate with one another directly for purposes of reaching agreement under this Article.


4. Any agreement between the Competent Authorities of two or more Contracting Parties shall be effective only between those Contracting Parties.


5. Where two or more Contracting Parties are unable to reach agreement, as contemplated in this Article, the matter shall be resolved as stipulated in the dispute resolution provisions of the Rules and Procedures of the African Tax Administration Forum.


6. At the request of one or more of the Contracting Parties, the Executive Secretary may convene a meeting of the Competent Authorities or their representatives, to discuss significant matters related to interpretation or implementation of this Agreement.