BMF-010221/0402-IV/8/2019

  Consultation agreement On the basis of a mutual agreement procedure according to Article 26 paragraph 3 of the Convention between the Republic of Austria and the Netherlands for the Avoidance of Double Taxation with respect to Taxes on Income and Capital signed on 1 September 1970 as amended by the Protocol signed on 18 December 1989, the Protocol signed on 26 November 2001, the Protocol signed on 8 October 2008 and the Protocol and the Additional Protocol signed on 8 September 2009 (the "Convention"), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the Republic of Austria and by the Kingdom of the Netherlands on 7 June 2017 (the "MLI"), the competent authorities of the Republic of Austria and the Kingdom of the Netherlands agree to the following: In order to ensure effective implementation of any agreement reached on the basis of Article 26 of the Convention before the entry into effect of the MLI, such agreement shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. This consultation agreement shall also apply to all mutual agreement procedures pending at the time of signature of this agreement.   Bundesministerium für Finanzen, 13. Jänner 2020