Common use of MUTUAL AGREEMENT PROCEDURE Clause in 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 24 (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.

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 24 (Non-discrimination)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 Convention.

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 person's case comes under paragraph 1 of Article 24 (Non-discrimination)23, 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.

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 24 (Non-discrimination)24, 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 this Convention.

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 24 (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.

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 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 the case comes under paragraph 1 of Article 24 (Non-discrimination)26, 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.

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 notwithstanding the remedies provided by the domestic law taxation laws 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 (1) of Article 24 (Non-discrimination)24, to that of the Contracting State of which he or she 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.

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 24 (Non-discrimination)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 Convention.

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 or, if his case comes under paragraph 1 of Article 24 (Non-discrimination)23, to that of the Contracting State of which he is a nationalnational or citizen. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 24 (Non-discrimination)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.

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 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 24 (Non-discrimination)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.

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 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 24 (Non-discrimination)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.

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 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 24 (Non-discrimination)20, 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.

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 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 l of Article 24 (Non-discrimination)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.

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 24 (Non-discrimination)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.

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 its 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 24 25 (Non-discriminationDiscrimination), 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.

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 24 (Non-discrimination)23 of this Convention, 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.

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 24 (Non-discrimination), 22 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.

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 ConventionAgreement, he may, irrespective of the remedies provided by the domestic law taxation 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 (1) of Article 24 (Non-discrimination)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 Conventionthis Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident or 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 24 (Non-discrimination)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 Conventionthis 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 24 (Non-discrimination)24, to that of the Contracting State of which he is a national. The case must be presented within three years from form the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of measures adopted by 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 24 (Non-discrimination)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.

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 24 (Non-discrimination)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 Convention.

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 that person’s case comes under paragraph 1 of Article 24 (Non-discrimination)25, 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 Convention.

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 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 24 (Non-discrimination)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 ConventionAgreemet.

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 24 (Non-discriminationDiscrimination), 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 which gives rise to taxation not in accordance with the provisions of the ConventionAgreement.

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 24 (Non-discrimination)24, to that of the Contracting Con- tracting 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.

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 24 (Non-discrimination)23, to that of the Contracting State of which he is a national. The case must be presented within with- in three years from the first notification of the action resulting in taxation not in accordance accord- ance with the provisions of the Convention.

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 24 (Non-discrimination)25, 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.

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 24 (Non-discrimination)25, to that of the Contracting Con- tracting 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.

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 that person’s case comes under paragraph 1 of Article 24 (Non-discrimination)23, to that of the Contracting State of which he that person is a national. The case must be presented within three five years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.

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 24 (Non-discrimination)25, 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 Conventionthis 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 StatesXxxxxx, 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 24 (Non-discrimination)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 Convention.

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 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 24 (Non-discrimination)22 of this Convention, 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.

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 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 24 (Non-discrimination)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 Convention.

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 ac- cordance 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 24 (Non-discrimination)article 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 ac- tion resulting in taxation not in accordance with the provisions of the Convention.

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 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 24 (Non-discrimination)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.

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 24 (Non-discrimination)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 this Convention.

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 24 (Non-discrimination)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 the Convention.

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 laws of those States, present his case to the competent authority of the Contracting State state of which he is a resident or, if his this case comes under paragraph 1 of Article 24 (Non-discrimination)24, to that of the Contracting State of which he is a national. The case must be presented within three years from the first First notification of the action resulting in taxation not in accordance with the provisions of the this Convention.

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 Convention, he or she may, irrespective of the remedies provided by the domestic law laws 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 Paragraph 1 of Article 24 (Non-discrimination)25, 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 Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is resident of a Contracting State considers that the actions of one or both competent authorities 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 24 (Non-discrimination)24, 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.

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 provi- sions 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 Con- tracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 24 (Non-discrimination)24, 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 re- sulting in taxation not in accordance with the provisions of the Convention.

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 24 (Non-discrimination)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.

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 24 (Non-discrimination)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.

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 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 24 (Non-discrimination)24, 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 this Convention.

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 24 (Non-discrimination)24, 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.

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 24 (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.

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 24 (Non-discrimination)24, 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.

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 24 (Non-discrimination), 25 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both I 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 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 24 22 (Non-discriminationNon- Discrimination), 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 Convention.

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 24 (Non-discrimination)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 Convention.

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 24 (Non-discrimination)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 Convention.

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 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 24 (Non-discrimination)24, to that of the Contracting State of which he is a nationalcitizen. 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.

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 24 (Non-discrimination)22, to that of the Contracting State of which he is a national. The case must be presented within three 3 (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 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 24 (Non-discrimination)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 actions resulting in taxation not in accordance with the provisions of the Convention.

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 no t 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 24 (Non-discrimination)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 Convention.

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 24 (Non-discrimination)24, to that of the Contracting State of which he is a national. 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.

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 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 24 (Non-discrimination)23, 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.

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 24 (Non-discrimination), 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 this Convention.

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 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 24 (Non-discrimination)24, 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 Convention.

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 m 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 24 (Non-discrimination)23 of the Convention, to that of the Contracting State of which he is a national. The case casу 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 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 24 (Non-discrimination)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 this Convention.

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 24 23 (Non-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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will wi l result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective ir espective 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 24 (Non-discrimination)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 Convention.

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 24 (Non-discrimination)24, 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.

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 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 24 23 (Non-discriminationDiscrimination), 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 which gives rise to taxation not in accordance with the provisions of the Convention.

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 24 (Non-discrimination)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 this Convention.

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 24 23 (Non-discrimination), 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 which gives rise to taxation not in accordance with the provisions of the Convention.

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 24 (Non-discrimination)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 Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result resuh for him in taxation not in accordance with the provisions of this Convention, 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 conies under paragraph 1 of Article 24 23 (Non-discriminationNon- 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 which gives rise to taxation not in accordance with the provisions of the Convention.

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 I of Article 24 (Non-discrimination)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 Convention.

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 that person is a resident or, if his that person’s case comes under paragraph 1 of Article 24 (Non-discrimination)23, 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 Convention.

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 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 24 22 (Non-discriminationDiscrimination), 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 Convention.

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 24 (Non-discrimination)26 of this Convention, 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.

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 or, if his case comes under paragraph 1 of Article 24 (Non-discrimination)24, 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.

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 24 (Non-discrimination)25, 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.

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 laws of those States, present his case to the competent authority of the Contracting State of which he is a resident oror , if his case comes under paragraph 1 of Article 24 25 (Non-discriminationNon- Discrimination), 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 this Convention.

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 24 (Non-discrimination)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 Convention.

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 provision 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 24 (Non-discrimination)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 Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 24 (Non-discrimination)25, 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.

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 24 (Non-discrimination)24, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 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 or, if his case comes under paragraph 1 of Article 24 (Non-discrimination)24, to that of the Contracting State of which he is a national. The This case must be presented within three two years from of the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the Convention.

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 24 (Non-discrimination)22, 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.

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 24 (Non-discrimination)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 first notification of the action resulting in taxation not in accordance with the provisions of the Convention.

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 24 (Non-discrimination)24, 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 this Convention.

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 24 23 (Non-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.

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 provision 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 24 (Non-discrimination)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 Convention.

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 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 24 (Non-discrimination)23, 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 Convention.

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 24 (Non-discrimination)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 Convention.

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 24 (Non-discrimination)25, 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 this Convention.

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 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 24 (Non-“Non- discrimination”), 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 Convention.

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 24 (Non-discrimination)22, 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.

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 24 (Non-discrimination)25 of this Convention, 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.

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 notwithstanding the remedies provided by the domestic law of those StatesStates , present his case to the competent authority of the Contracting State of which he is a resident oror , if his case comes under paragraph 1 of Article 24 (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.

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 24 (Non-discrimination)22, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 24 (Non-discrimination)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.

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 24 (Non-discrimination)26, 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.

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 24 (Non-discrimination)24, to that of the Contracting Contract- ing 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 provi- sions of the Convention.

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 24 (Non-discrimination)25 of this Convention, 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.