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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either State.

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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, in the case of an individual, to that of the Contracting State of which he is a citizen. 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. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with this Agreement, the provisions of this Convention, he person may, irrespective of the remedies provided by the domestic law of those States, and States concerning taxes to which the time limits prescribed in such laws for presenting claims for refundsAgreement applies, present his a case to the competent authority of either Statethe Contracting State of which the person 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph 1 of Article 26, 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 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 ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Contracting State. 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his a case to the competent authority of either the Contracting State of which the person is a resident. The case must be presented within the time limits provided for in the domestic law of the Contracting State.

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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 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 this Agreement, the provisions of this Convention, he person may, irrespective of the remedies provided by the domestic law of those States, and States concerning taxes to which the time limits prescribed in such laws for presenting claims for refundsAgreement applies, present his a case to the competent authority of either Statethe Contracting State of which the person 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 Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 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 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 laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where When 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident 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 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a 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 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, and the time limits prescribed in such laws for presenting claims for refundsa refund, present his case to the competent authority of either Contracting State.

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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph I of Article 24, 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 the Agreement.

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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 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 the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. 01 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident, 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. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with this Agreement, the provisions of this Convention, he person may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refundsStates concerning taxes to which this Agreement applies, present his a case to the competent authority of either Statethe Contracting State of which the person 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 this 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 ConventionArticle, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 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 the 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting [*65] 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of notwithstanding the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph 1 of Article 22, 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 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 s Convention, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph 1 of Article 26, 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 provisi the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case address to the competent authority of either Statethe 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 this 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Contracting State. 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 (or in the case of tax collected at source within three years from the date of collection).

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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident.

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, and the time limits prescribed in such laws for presenting claims for refunds, present his a case to the competent authority of either Statethe Contracting State of which the person is a resident 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 three years from the first notification of the action resulting in taxation in accordance with the provisionsof the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, if his case comes under Article VIII(1), 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 resulting in taxation not in accordance with the provisions of the 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident. The case must be presented within 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 in taxation not in accordance with the provisions provi- sions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Contracting State. 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 ConventionConventions, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case address to the competent authority of either Statethe 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the 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 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 ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those Contracting States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident. The case must be presented within threeyears 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 resident of 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 the provisions of this Convention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident. The case must be presented within three years of the first notice of the action which results in taxation not in accordance with 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either State.taxation

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both more of the Contracting States result results 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, if is 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 two 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or national. The case must be presented within five 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 ConventionAgreement, he may, irrespective of the remedies provided by the domestic law laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Contracting State. 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 two (2) 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident. The case must be presented within 3 (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 of 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 the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic national law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, if his case comes under paragraph 1 of article 23 of this Agreement, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers finds that the actions of one or both of the Contracting States result in, or will result for him in in, a taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by for in the domestic law regulations of those States, and the time limits prescribed in such laws for presenting claims for refunds, present submit his case to the competent authority of either Contracting State. The case should be brought within three years of the first notification of the action leading to a tax contrary to the provisions of 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 taxationnot in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident 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 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, Agreement he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident 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 in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case in written form to the competent authority of either Statethe Contracting State of which he is a resident, indicating the reasons for the review of the decision of taxation. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. Where a ) Any person who 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 Convention may, irrespective of notwithstanding the remedies provided by the domestic law laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Contracting State.. Such presentation must be made within the period of time prescribed for the filing of a claim for credit or refund under Article

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, Agreement he may, irrespective of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation taxa- tion 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, and the time limits prescribed in such laws for presenting claims for refunds, present his a case to the competent authority of either Statethe Contracting State of which the person is a resi- dent. The case must be presented within three years from the first notification of the action resulting in taxation not in ac- cordance with the provisions of the 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe State of which he is a resident or 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 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 the 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 laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 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 ConventionAgent, he may, irrespective irrespetive of the remedies provided by the domestic law of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident or national.

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 States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 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 laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe 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 two 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 person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law national laws of those States, and the time limits prescribed in such laws for presenting claims for refunds, present his case to the competent authority of either Statethe Contracting State of which he is a resident 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 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, and the time limits prescribed in such laws for presenting claims for refunds, present his case address to the competent authority of either Statethe Contracting State of which that person is a resident or, if that person's case comes under paragraph 1 of Article 24, to that of the Contracting State of which that person is a national, an application in writing stating the grounds for claiming the revision of such taxation.

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, and the time limits prescribed in such laws for presenting claims for refunds, present his that case to the competent authority of either Contracting State. 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.