The mutual agreement procedure takes place in two phases: (i) the second sentence “any agreement obtained is implemented independently of a time limitation in the domestic law of the conventional courts” is an indeterminate obligation. In other words, as many years as the contractual jurisdiction that made the initial adjustment has diminished, the company should be ensured an appropriate adjustment in the other jurisdiction of the treaty. Some States Parties may consider such an indeterminate obligation to be unreasonable. There are tax information exchange agreements to promote international tax cooperation and combat tax evasion. Many Hong Kong double taxation conventions contain information provisions. Hong Kong has also signed a series of stand-alone agreements on the exchange of tax information. They generally contain the following provisions: 1. Where a person believes that the actions of one or both of the jurisdiction of the contract do not involve or do not involve that person in accordance with the provisions of the covered tax treaty, irrespective of the remedies provided by the domestic law of those territories, that person may refer the matter to the competent authority of the treaty jurisdiction. , whose resident or resident is concerned when the case raised by that person falls within a provision of a covered tax treaty relating to non-discrimination on the basis of nationality and the determination of the contractual jurisdiction of which that person is a national; and the competent authority of that contracting court conducts a bilateral procedure of notification or consultation with the competent authority of the other jurisdiction of the treaty in cases where the competent authority for which the procedure of mutual agreement has been submitted does not consider that the objection of the subject is justified.
B) contracting courts do not include the profits of a business and the taxes paid to it, but that, because of the conditions set out in a provision of the guaranteed tax treaty for related companies, the agreed-upon deadline between the two contractual regulations was not created from the end of the fiscal year in which the profits would have been generated by the company (this provision applies to the company in case of fraud , gross negligence or premeditation does not apply. Shipowners are at particularly high risk of double taxation.