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 Agreement, 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, 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.
Appears in 198 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 AgreementConvention.
Appears in 176 contracts
Samples: Double Tax Agreement, Taxation Avoidance Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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 2425, 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 AgreementConvention.
Appears in 66 contracts
Samples: Taxation Avoidance Agreement, api-portal.gov.uz, www.hacienda.gob.es
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2425, 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.
Appears in 59 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2423, 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.
Appears in 56 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 AgreementConvention, 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 2425, 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 AgreementConvention.
Appears in 27 contracts
Samples: internationaltaxtreaty.com, www.ris.bka.gv.at, www.ris.bka.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 24 contracts
Samples: Agreement, Mauritius Double Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 24 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 Agreement, 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, 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 Agreement.
Appears in 24 contracts
Samples: Double Taxation Agreement, Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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 2422, 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 AgreementConvention.
Appears in 21 contracts
Samples: Agreement, Agreement, legimonaco.mc
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 Agreement, 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 2423, 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.
Appears in 19 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2422, 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.
Appears in 19 contracts
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 AgreementConvention.
Appears in 18 contracts
Samples: factura.soliq.uz, internationaltaxtreaty.com, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 18 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 Agreement, 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 2426, 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.
Appears in 17 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 13 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 AgreementConvention, 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, 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 AgreementConvention.
Appears in 12 contracts
Samples: gta.gov.qa, www.nalog.ru, kgd.gov.kz
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 AgreementConvention, 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, 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 AgreementConvention.
Appears in 11 contracts
Samples: www.mof.go.jp, cdn.www.gob.pe, assets.gov.ie
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2425, 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.
Appears in 11 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 AgreementConvention, 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 2423, 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 AgreementConvention.
Appears in 8 contracts
Samples: www.ris.bka.gv.at, www.ris.bka.gv.at, ris.bka.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, 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 2422, 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 Agreement.
Appears in 8 contracts
Samples: Agreement, Agreement, South African Revenue
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 AgreementConvention, 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 2425, 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 AgreementConvention.
Appears in 8 contracts
Samples: internationaltaxtreaty.com, internationaltaxtreaty.com, soliq.uz
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 Agreement, 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 2425, 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 Agreement.
Appears in 8 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 7 contracts
Samples: Agreement, Agreement, Double Taxation 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 AgreementConvention, 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 2422, 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 AgreementConvention.
Appears in 7 contracts
Samples: Artistes and Sportsmen, www.bundeskanzleramt.gv.at, data.parliament.uk
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 Agreement, he may, irrespective of notwithstanding 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 of Article 2426, 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 Agreement.
Appears in 6 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 6 contracts
Samples: Agreement, Agreement, www.sars.gov.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2424 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 this Agreement.
Appears in 6 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
Appears in 6 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
Appears in 6 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 Agreementthis Convention.
Appears in 6 contracts
Samples: www.mof.gov.kn, internationaltaxtreaty.com, backoffice3.titanka.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 6 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 the provisions 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 this Agreement.
Appears in 6 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2425, 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 Agreement.
Appears in 6 contracts
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 AgreementConvention.
Appears in 6 contracts
Samples: kgd.gov.kz, 360.lexisnexis.at, www.parlament.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance accodance with the provisions of this Agreement, 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 2423, 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.
Appears in 5 contracts
Samples: www.bphn.go.id, Pengesahan Agreement, Pengesahan 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 AgreementConvention, 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, 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 Agreementthis Convention.
Appears in 5 contracts
Samples: rdb.manz.at, www.parlament.gv.at, www.parlament.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that than 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 AgreementConvention, 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 2421, 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 AgreementConvention.
Appears in 5 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 5 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2424 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.
Appears in 5 contracts
Samples: Agreement, Agreement, advokatmoldova.ru
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 Agreement, 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, 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 Agreement.
Appears in 5 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, to 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.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 5 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 of or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalnational of. 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.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Agreement, Double Taxation Avoidance Agreement
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 Agreement, 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, 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.
Appears in 4 contracts
Samples: Agreement, Iran Double Taxation Agreement, 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 in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 4 contracts
Samples: Taxation Avoidance Agreement, Agreement, Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2423, 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.
Appears in 4 contracts
Samples: Double Taxation Agreement, www.incometaxindia.gov.in, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of notwithstanding 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 of Article 2425, 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.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Tax Agreement, Double Taxation Avoidance Agreement
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 AgreementConvention, 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 2425, 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 AgreementConvention.
Appears in 4 contracts
Samples: internationaltaxtreaty.com, www.rs.ge, mof.ge
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 Agreement, 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, 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.
Appears in 4 contracts
Samples: Agreement, www.incometaxindia.gov.in, Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident 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 Agreement, 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, 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.
Appears in 4 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
Appears in 4 contracts
Samples: Double Taxation Agreement, Agreement, www.mra.mu
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 AgreementConvention, 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 2420, 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 AgreementConvention.
Appears in 4 contracts
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 Agreement, 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, 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.
Appears in 4 contracts
Samples: Agreement, Agreement, Taxation Avoidance Agreement
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 Agreement, he may, irrespective of notwithstanding 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 2425, 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.
Appears in 4 contracts
Samples: Double Taxation Avoidance Agreement, Agreement, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 AgreementConvention.
Appears in 4 contracts
Samples: internationaltaxtreaty.com, www.vmi.lt, www.caribbeanelections.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 3 contracts
Samples: gta.gov.qa, Double Taxation Avoidance Agreement, backoffice3.titanka.com
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 Agreement, 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 2423, 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 Agreement.
Appears in 3 contracts
Samples: www.bphn.go.id, www.bphn.go.id, jdih.bkpm.go.id
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 Agreement, 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 2425, 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, he that person 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 that person is a resident or, if his that person's case comes under paragraph 1 of Article 2423, 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 this Agreement.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, internationaltaxtreaty.com, www.sii.cl
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 Agreement, 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 2423, 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.
Appears in 3 contracts
Samples: internationaltaxtreaty.com, www.dfa.ie, www.taxfind.ie:443
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States territories result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those Statesthe territory, present his case to the competent authority of the Contracting State territory of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State territory of which he is a citizen or 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.
Appears in 3 contracts
Samples: Agreement, Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 25 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 3 contracts
Samples: cacollege.co.za, www.mra.mu, cacollege.co.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of competent authorities of one or both of the Contracting States territories result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those Statesterritories, present his case to the competent authority of the Contracting State territory of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State territory 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.
Appears in 3 contracts
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 AgreementConvention.
Appears in 3 contracts
Samples: www.ris.bka.gv.at, www.ris.bka.gv.at, www.parlament.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
Appears in 3 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2424 (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 which gives rise to taxation not in accordance with the provisions of the Agreement.
Appears in 3 contracts
Samples: Agreement, bir-cdn.bir.gov.ph, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
Appears in 3 contracts
Samples: Treaty Series, www.revenue.ie, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 AgreementConvention.
Appears in 3 contracts
Samples: Agreement, www.incometaxindia.gov.in, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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 2425, 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 AgreementConvention.
Appears in 3 contracts
Samples: www.parlament.gv.at, www.ris.bka.gv.at, rdb.manz.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States territories result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those Statesterritories, present his case to the competent authority of the Contracting State territory of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State territory 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.
Appears in 3 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
Appears in 3 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, 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, 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 AgreementConvention.
Appears in 3 contracts
Samples: www.gov.si, sfs.md, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2425 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.
Appears in 3 contracts
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 Agreement, 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, 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 Agreement.
Appears in 3 contracts
Samples: bphn.jdihn.go.id, www.flevin.com, jdih.bpk.go.id
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 AgreementConvention, 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, 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 AgreementConvention.
Appears in 3 contracts
Samples: Taxation Avoidance Agreement, internationaltaxtreaty.com, mattarlaw.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2425 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 this Agreement.
Appears in 2 contracts
Samples: internationaltaxtreaty.com, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States Parties result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those StatesParties, present his case to the competent authority of the Contracting State Party of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State Party of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.
Appears in 2 contracts
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 Agreement, 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, 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 Agreement.
Appears in 2 contracts
Samples: Pengesahan Agreement, Pengesahan 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 Agreement, he may, irrespective of the remedies provided by the domestic law of those States, States present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 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.
Appears in 2 contracts
Samples: Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers consi-ders 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 Agreement, 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 2425, 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.
Appears in 2 contracts
Samples: Agreement, www.taxsutra.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreementthis Agreement .
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 2 contracts
Samples: Zambia Double Taxation Agreement, Zambia Double Taxation 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 Agreement, 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 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 Agreement.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 2 contracts
Samples: South African Revenue, 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 Agreement, 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 case comes under paragraph 1 of Article 24, 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 Agreement.
Appears in 2 contracts
Samples: www.taxpolicy.ird.govt.nz, 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 Agreement, 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, 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 Agreement.
Appears in 2 contracts
Samples: Pengesahan Agreement, Pengesahan Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident 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 Agreement, 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, 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.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, lampiran1.hasil.gov.my
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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 2423, 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 Agreement.
Appears in 2 contracts
Samples: Taxation Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 2 contracts
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 Agreement, he may, irrespective of notwithstanding 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 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 this Agreement.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 2 contracts
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 Agreement, he may, irrespective of notwithstanding 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 of Article 2425, 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.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, phl.hasil.gov.my
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 Agreement, 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 2425, 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.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
Appears in 2 contracts
Samples: auditors.am, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of notwithstanding 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 of Article 2426, to that of the Contracting State of which he is a nationalnational . 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.
Appears in 2 contracts
Samples: Taxation Avoidance Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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 Agreement.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of oft one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, 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, 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.
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