What is the procedure for applying to the US competent authority for zero under Article 23(6) and how long will it take?
A taxpayer that is not otherwise entitled to benefits under Article 23 but believes it may be entitled to such benefits under the discretionary provision of Article 23(6) should submit that request to: Director International Internal Revenue Service Attn: LM:IN:TT 1111 Constitution Avenue, NW Washington, DC 20224 For guidance in preparing requests for discretionary benefits, taxpayers should consult the U.S. Treasury Technical Explanation of Articles 10 and 23 of the Treaty (see http://www.ustreas.gov/offices/tax-policy/library/teus-uk.pdf), and the U.S. Internal Revenue Service’s Revenue Procedure 2002-52, with particular reference to Sections 3.08 and 4 (see http://www.irs.gov/individuals/article/0,,id=96945,00.htm” target= “_blank). The IRS Internal Revenue Manual Exhibit 4.60.3-3, at http://www.irs.gov/irm/page/0,,id%3D21706,00.htm” target= “_blankl#ss57, provides detailed guidance regarding information that should be submitted in connection with any request for a discretionary det
