A simultaneous tax examination requires the cooperation of tax administration officials located in the two States who will simultaneously but independently examine the taxpayer(s) within their jurisdiction. They will try as far as possible to synchronize their work schedules, since potential double taxation issues may arise in the course of simultaneous tax examinations:
- (a)
- the taxpayers will be able to present a request for the opening of the mutual agreement procedure at an earlier stage than they would have if there was no simultaneous examination; (b)
- the representatives of the competent authorities will be able to build up more complete factual evidence for those tax adjustments for which the mutual agreement procedure may be requested.