Common use of MUTUAL AGREEMENT PROCEDURE Clause in Contracts

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State one of the States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or citizen.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person who is a resident of a one of the Contracting State States 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 this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, may notwithstanding the remedies provided by the national laws of those States, present his the case to the competent authority of the Contracting State of which he is a resident. The case must be presented within four years from the date of assessment or of the withholding of tax at the source whichever is later.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph (1) of Article 25 of this Agreement, to that of the Contracting State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident. 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action which gives rise to taxation not in accordance with the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national taxation laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 25, to that of the 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding without prejudice to the remedies provided by the national laws of those States, present his case address to the competent authority of the Contracting State of which he is a resident, an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action which gives rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State considers that the actions of the competent authority 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his a case to the competent authority of the Contracting State of which he that person is a resident. 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case in writing to the competent authority of the Contracting State of which he is a resident. The case must be presented within two years from the first notification of the action which gives rise to taxation not in accordance with the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting States of which he is a national. This case must be presented within two years from the first notification of the action giving rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a one of the Contracting State States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him in taxation not in accordance with this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national domestic laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a one of the Contracting State States considers that the actions of the taxation authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national domestic laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph (1) of Article 22 of this Agreement, to that of the Contracting State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a one of the Contracting State States considers that the actions of one or both of the Contracting States result or will result for him in taxation not laws in accordance with this Conventionforce in the Contracting States, he present may, notwithstanding the remedies provided by the national taxation laws of those in force in the Contracting States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national domestic 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 date of the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a one of the Contracting State States 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 this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within 3 years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States State result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, notwithstanding the remedies provided by the national domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the State or 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within five years of the date of receipt of notice of the action which gives rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident. 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph (1) of Article 26 of this Convention, to that of the Contracting State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State considers that the actions of one or both the competent authority of the a Contracting States State result or will result for him the person in taxation not in accordance with the provisions of this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national laws of those the Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within four years from the first notification of the action giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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, notwithstanding irrespective of the remedies provided by the national domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, may notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The claim must be lodged within two years from the date on which the tax was notified or withheld at the source or within two years of the entry into force of this Convention, whichever is the later.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 this ConventionAgreement, he may, notwithstanding saving the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within three years of the first notification of the action giving rise to taxation not in accordance with the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State 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 this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national domestic laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 ConventionAgreement, he may, notwithstanding the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph (1) of Article 26 of this Agreement, to that Contracting State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. This case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States State result or will result for him in taxation not in accordance with the provision of this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national domestic laws of those StatesState, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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, notwithstanding irrespective of the remedies provided by the national domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. If his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a residentresident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person is a national. The case must be presented within the period prescribed by the domestic law of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State 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 this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within 3 years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 this Convention, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, Convention he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. This case must be presented within two years from the first notification of the action giving rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a one of the Contracting State States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him in taxation not in accordance with this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State 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 this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within 4 years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within three years of the date of receipt of notice of the action which gives rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 provisions of this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a one of the Contracting State States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, Agreement he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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, notwithstanding the independently of any remedies provided by for under the national domestic laws of those States, present submit his case to the competent authority of the Contracting State of which he is a resident. The case must be submitted within three years after the first notification of the action resulting in taxation which is not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is resident of a Contracting State considers that the actions of the competent authority 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, notwithstanding irrespective of the remedies provided by the national domestic laws of those States, present his case to the competent authority of the Contracting State of which he the person is a resident. 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person who is a resident of a one of the Contracting State States considers that the actions of the taxation authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a one of the Contracting State States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him in taxation for the person not in accordance with this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24 to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State one of the States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 23, to that of the State of which he is a national. This case must be presented within two years from the first notification of the action giving rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. 1 Where a person who is a resident of a Contracting State 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 this ConventionAgreement, he the person may, notwithstanding the remedies provided by the national domestic laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a Contracting State considers that the actions of the competent authority of one or both of the Contracting States result or will result for him in taxation not in accordance with this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a one of the Contracting State States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case in writing to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State one of the States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding irrespective of the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. (1 ) Where a resident of a Contracting State considers that the actions of one taken by a Contracting State or both of the Contracting States result or will result for him in taxation not in accordance with this ConventionConvention imposition State, he may, notwithstanding the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentnational . 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.

MUTUAL AGREEMENT PROCEDURE. 1. ) Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting States of which he is a national. This case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. This case must be presented within two years from the first notification of the action giving rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. - 1. ) Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The claim must be lodged within two years from the date of the assessment or of the withholding of tax at the source whichever is the later.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State 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 this Convention, he that person may, notwithstanding irrespective of the remedies provided by the national laws 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 that person is a residentresident or, if the case comes under paragraph 1 of Article 25 of this Convention, to that of the Contracting State of which that person is a national.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws of those States, present his case to the competent Competent authority of the Contracting State of which he is a resident, or if his case comes under paragraph (1), Article 25, to 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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, notwithstanding irrespective of the remedies provided by the national domestic laws of those the Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action which results in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting States of which he is a national. This case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will may result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, Convention he may, notwithstanding the remedies provided by the national domestic laws of those States, present his case to the competent authority authorities of the Contracting State of which he is a resident, or, where his case comes under Article 25, paragraph 1, to the competent authorities of the Contracting State of which he is a national. Such case must be submitted within three years from the first notification of the action which results in taxation not in accordance with this Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The claim has to be lodged within a period of two years from the date notification of the tax lastly imposed or in the case of witholding at source from the date of the payment of the income subject to such withholding.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in double taxation not in accordance with prohibited by this Convention, he may, notwithstanding independently of the remedies provided by the national laws of those States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming revision of his taxation. The said application must be submitted before the expiry of a period of two years from the notification of liability to or the deduction at source of the second charge to tax.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case address to the competent authority of the Contracting State of which he that person is a residentresident an application in writing stating the grounds for claiming the revision of such taxation.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result results or will result for him in taxation not in accordance with this ConventionAgreement, he may, notwithstanding the remedies provided by the national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years of the date of such action or the latest of such actions as the case may be.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding without prejudice to the remedies provided by the national laws of those States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the notification of the action which gives rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national taxation 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 25, to that of the 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 this Agreement

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result result, or will result result, for him in taxation not in accordance with the provisions of this Convention, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action giving rise to taxation not in accordance with the provisions of the Convention.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a Contracting State contracting state considers that the actions of one or both of the Contracting States contracting states result or will result for him in taxation not in accordance with the provisions of this Conventionagreement, he may, notwithstanding the remedies provided by the national laws domestic law of those Statesstates, present his case to the competent authority of the Contracting State contracting state of which he is a residentresident or, if his case comes under paragraph (1) of Article 26 of this agreement, to that contracting state of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding without prejudice to the remedies provided by the national laws of those States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming the revision of such taxation. To be admissible, the said application must be submitted within two years from the first notification of the action resulting in taxation not in accordance with this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within three years of the first notification of the action which gives rise to the taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a one of the Contracting State States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within two years from the first notification of the action.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented to the other Contracting State within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or if his case comes under paragraph 1 of Article 26, 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding the remedies provided by the national taxation laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting States of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years of the date of such action or the latest of such actions as the case may be.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. The claim must be lodged within two years from the date of the assessment or of the withholding of tax at the source whichever is the later.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws domestic law of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those these States, present his case to the competent authority of the Contracting State of which he is a resident. The claim must be lodged within two years from the date of the assessment or of the withholding of tax at the source whichever is the later.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within two years from the first notification of the action giving rise to taxation not in accordance with the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 this ConventionAgreement, he may, notwithstanding irrespective of the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the other Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.