Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, and
Appears in 44 contracts
Samples: www.mofa.go.jp, www.mof.go.jp, www.ilajapan.org
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, and
Appears in 38 contracts
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this ConventionAgreement, and
Appears in 13 contracts
Samples: Ataf Model Agreement, Agreement, Agreement
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State Party on the basis that the actions of one or both of the Contracting States Parties have resulted for that person in taxation not in accordance with the provisions of this ConventionAgreement, and
Appears in 12 contracts
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, ; and
Appears in 11 contracts
Samples: Agreement, archiv.llv.li, internationaltaxtreaty.com
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this ConventionAgreement, and
Appears in 9 contracts
Where. (a) under paragraph 1, a person has presented a case to the competent authority authori- ty of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance accord- ance with the provisions of this Convention, and
Appears in 2 contracts
Samples: app.parlamento.pt, app.parlamento.pt
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting Con- tracting States have resulted for that person in taxation not in accordance with the provisions of this Convention, and
Appears in 1 contract
Samples: www.sif.admin.ch
Where. (a) 1. under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this ConventionAgreement, and
Appears in 1 contract
Samples: www.bundesfinanzministerium.de
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person him in taxation not in accordance with the provisions of this Convention, and
Appears in 1 contract
Samples: fdfa.be
Where. (a) under paragraph 1, a person has presented a case to the competent authority of a Contracting State state on the basis that the actions of one or both of the Contracting States states have resulted for that person in taxation not in accordance with the provisions of this Convention, and
Appears in 1 contract
Samples: assets.publishing.service.gov.uk
Where. (a) under paragraph 1, a person has presented a case, except a case that is not eligible for arbitration, to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have resulted for that person in taxation not in accordance with the provisions of this ConventionAgreement, and
Appears in 1 contract
Samples: Amending the Agreement
