MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 62 contracts
Samples: Taxation Avoidance Agreement, www.hacienda.gob.es, www.spenceclarke.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 61 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 29 contracts
Samples: mof.gov.sa, www.mof.gov.sa, www.mof.gov.sa
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 24 contracts
Samples: Agreement, Mauritius Double Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2522, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 19 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 17 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 16 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 16 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2526, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 15 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States Parties result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those StatesParties, present his case to the competent authority of the Contracting State Party of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State Party of which he is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 14 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 14 contracts
Samples: www.mof.go.jp, Convention, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case address to the competent authority of the Contracting State of which he is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the Convention.
Appears in 12 contracts
Samples: kgd.gov.kz, internationaltaxtreaty.com, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 12 contracts
Samples: www.jlsk-group.com, Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 10 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 10 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 9 contracts
Samples: www.sars.gov.za, internationaltaxtreaty.com, www.into-sa.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 9 contracts
Samples: Agreement, Agreement, www.sars.gov.za
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 8 contracts
Samples: data.qanoon.om, www.bundesfinanzministerium.de, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 8 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 8 contracts
Samples: mof.ge, www.llv.li, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 8 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 8 contracts
Samples: assets.publishing.service.gov.uk, www.rsl.org.ls, Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, States present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 7 contracts
Samples: www.hacienda.gob.es, www.hacienda.gob.es, www.hacienda.gob.es
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 7 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 6 contracts
Samples: Agreement, internationaltaxtreaty.com, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 6 contracts
Samples: Agreement, santoslolowang.com, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident resident, or, if his case comes under paragraph 1 of Article 2526, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 6 contracts
Samples: Double Taxation Agreement, www.spenceclarke.com, www.incometaxindia.gov.in
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, 24 to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 6 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 5 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident or a national of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 5 contracts
Samples: www.firs.gov.ng, www.orandcconsultants.com, aopsglobal-ng.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523 of this Agreement, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 5 contracts
Samples: internationaltaxtreaty.com, Agreement, Treaty Series 2011
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 5 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 5 contracts
Samples: Agreement, Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 5 contracts
Samples: Treaty Series 2016, www.ujp.gov.mk, www.revenue.ie
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 5 contracts
Samples: Agreement, www.sars.gov.za, www.sars.gov.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident orresident, or if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 5 contracts
Samples: into-sa.com, www.emta.ee, www.riigiteataja.ee
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case address to the competent authority of the Contracting State of which he is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 4 contracts
Samples: www.nalog.ru, Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524 (Non-Discrimination), to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 4 contracts
Samples: www.emta.ee, www.emta.ee, auditors.am
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of the competent authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this ConventionAgreement, he the person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 4 contracts
Samples: www.legislation.gov.au, Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 4 contracts
Samples: South African Revenue, www.hacienda.gob.es, static.pmg.org.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he the person may, irrespective of the remedies provided by the domestic law of those States, present his the case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 4 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 4 contracts
Samples: www.mof.gov.sa, zatca.gov.sa, www.mof.go.jp
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State States of which he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 4 contracts
Samples: Agreement, Taxation Avoidance Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 4 contracts
Samples: www.ris.bka.gv.at, archiv.llv.li, www.parlament.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 4 contracts
Samples: Ataf Model Agreement, Double Taxation Agreement, Model Tax Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 25, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 4 contracts
Samples: South African Revenue, static.pmg.org.za, www.nyansa-africa.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a or national. The case must be presented within three years from of the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 4 contracts
Samples: franceintheus.org, franceintheus.org, www.irs.gov
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three 2 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 4 contracts
Samples: internationaltaxtreaty.com, www.multi-count.com, mattarlaw.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States Parties result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those StatesParties, present his case to the competent authority of the Contracting State Party of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State Party of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 4 contracts
Samples: Agreement, Agreement, Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under the paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: www.econ-e.gr, workarea.et-gw.eu, www.dinamiki.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 3 contracts
Samples: www.mof.gov.sa, zatca.gov.sa, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this ConventionAgreement, he the person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalState. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 3 contracts
Samples: www.aph.gov.au, treasury.gov.au, taxpolicy.crawford.anu.edu.au
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 3 contracts
Samples: South African Revenue, Double Taxation Agreement, Tax Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his case address to the competent authority of the Contracting State of which he that person is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case application must be presented submitted within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 3 contracts
Samples: assets.publishing.service.gov.uk, relotax.co.il, www.treaty-accord.gc.ca
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2522, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: internationaltaxtreaty.com, static.pmg.org.za, static.pmg.org.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 25, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: cacollege.co.za, cacollege.co.za, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: www.mof.gov.sa, www.mof.gov.sa, gstc.gov.sa
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with this Agreement, the provisions of this Convention, he person may, irrespective of the remedies provided by the domestic law of those StatesStates concerning taxes to which the Agreement applies, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 3 contracts
Samples: Agreement, Agreement, www.aph.gov.au
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident orresident, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 3 contracts
Samples: Agreement, Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 3 contracts
Samples: Convention, internationaltaxtreaty.com, www.llv.li
MUTUAL AGREEMENT PROCEDURE. 1. 1 - Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article 25(23), to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 3 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: South African Revenue, Taxation Avoidance Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: www.finanze.it, www.finanze.it, www.studiocerbone.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the receipt of the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: internationaltaxtreaty.com, internationaltaxtreaty.com, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a or national. The case must be presented within three 5 years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 3 contracts
Samples: www.unclefed.com, www.swissbanking.ch, www.irs.gov
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law laws of those States, present his case address to the competent authority of the Contracting State of which he that person is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: www.revenue.ie, internationaltaxtreaty.com, www.dfa.ie
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: South African Revenue, www.burs.org.bw, static.pmg.org.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, internationaltaxtreaty.com, lampiran1.hasil.gov.my
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523 of, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 3 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, Convention he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2526 (Non-Discrimination), to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: s3-ap-northeast-1.amazonaws.com, www.rd.go.th, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his case address to the competent authority of the Contracting State of which he that person is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: internationaltaxtreaty.com, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. 1 β Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25article 24, to that of the Contracting Con- tracting State of which he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: treaties.un.org, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident orresident, or if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: fdfa.be, www.dinamiki.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, States present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Convention, he the person may, irrespective of the remedies provided by the domestic law of those StatesStates concerning taxes to which this Convention applies, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he the person is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 2 contracts
Samples: archive.treasury.gov.au, www.aph.gov.au
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions action of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524 (Non-Discrimination), to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 2 contracts
Samples: www.ird.gov.tt, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2522, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthat Agreement.
Appears in 2 contracts
Samples: www.ujp.gov.mk, Treaty Series
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions action of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article 2524, to that of the Contracting State Suite of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: www.frcs.org.fj, www.frcs.org.fj
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524 (Non- discrimination), to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: www.gov.il, www.ncilawgroup.com
MUTUAL AGREEMENT PROCEDURE. When a person 1. Where a person considers Considers that the actions of one measures taken by a Contracting State or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionConvention taxation, he it may, irrespective of notwithstanding the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to 24 state that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 2 contracts
Samples: Taxation Avoidance Agreement, Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those the Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
Samples: www.iras.gov.sg, www.iras.gov.sg
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him or her in taxation not in accordance with the provisions of this ConventionAgreement, he or she may, irrespective of the remedies provided by the domestic law of those States, present his or her case to the competent authority of the Contracting State of which he or she is a resident or, if his or her case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he or she is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
Samples: internationaltaxtreaty.com, www.sars.gov.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, may irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 2 contracts
Samples: internationaltaxtreaty.com, auditors.am
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his the case to the competent authority of the Contracting State of which he that person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he that person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident resident, or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 2 contracts
Samples: France Russia, Belgium Russia
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case in writing to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2522, to that of the Contracting State of which he is a national. The This case must be presented within three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: Taxation Avoidance Agreement, assets.publishing.service.gov.uk
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2525 of this Agreement, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 2 contracts
Samples: mof.ge, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph paragraphs 1 and 2 of Article 2524, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
Samples: Agreement, botswanalaws.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524 is applicable, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: internationaltaxtreaty.com, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Convention, he the person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: www.aph.gov.au, treasury.gov.au
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three 2 years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
Samples: Agreement, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article 2522, to that of the Contracting State States of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: internationaltaxtreaty.com, theocharides.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2524 (Non- Discrimination), to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
Samples: www.swissbanking.ch, www.swissbanking.org
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 25, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 2 contracts
