Amendment of Article. 26 (a) In paragraph 1 of Article 26 (Mutual Agreement Procedure), the words “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.” are inserted immediately after the words “of which he is a resident.”; and (b) In paragraph 2 of Article 26 (Mutual Agreement Procedure), the words “Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States.” immediately after the words “not in accordance with this Convention.”.
Appears in 5 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
Amendment of Article. 26
(a) In paragraph 1 of Article 26 (Mutual Agreement Procedure), the words “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.” are inserted immediately after the words “of which he is a residentnational.”; and.
(b) In paragraph 2 of Article 26 (Mutual Agreement Procedure), the words “Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States.” are inserted immediately after the words “not in accordance with this Conventionthe Agreement.”.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement