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 196 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 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 92 contracts
Samples: Taxation Avoidance Agreement, archiv.llv.li, 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 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 61 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 AgreementConvention, 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 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementresident.
Appears in 31 contracts
Samples: 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 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 nationalresident. 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 Agreementthis Convention.
Appears in 29 contracts
Samples: mof.gov.sa, www.mof.gov.sa, www.mof.gov.sa
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 case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalresident. 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 16 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 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 AgreementConvention.
Appears in 15 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 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 14 contracts
Samples: www.mof.go.jp, Convention, 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 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.
Appears in 14 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 Agreementor citizen.
Appears in 12 contracts
Samples: www.unclefed.com, www.unclefed.com, tax.gov.ua
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 Agreement.
Appears in 12 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 address to the competent authority of the Contracting State of which he is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the AgreementConvention.
Appears in 12 contracts
Samples: kgd.gov.kz, 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 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 12 contracts
Samples: www.jlsk-group.com, Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person who is a resident of one of the Contracting States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalresident. The case must be presented within three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the this Agreement.
Appears in 10 contracts
Samples: www.spenceclarke.com, 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 resulting in taxation not in accordance with the provisions of the Agreement.
Appears in 10 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 this Agreement.
Appears in 10 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 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 10 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 9 contracts
Samples: www.sars.gov.za, internationaltaxtreaty.com, www.into-sa.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 may notwithstanding the remedies provided by the domestic law national laws of those States, present his the 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 nationalresident. The case must be presented within three four years from the first notification date of assessment or of the action resulting in taxation not in accordance with withholding of tax at the provisions of the Agreementsource whichever is later.
Appears in 8 contracts
Samples: Agreement, Tax 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 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 nationalresident. 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 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 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 8 contracts
Samples: data.qanoon.om, www.bundesfinanzministerium.de, 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, 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 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 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 Agreementthis Convention.
Appears in 8 contracts
Samples: mof.ge, www.llv.li, 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 Agreement.
Appears in 8 contracts
Samples: assets.publishing.service.gov.uk, www.rsl.org.ls, 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 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 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 7 contracts
Samples: Agreement, www.rs.ge, 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, to that of the Contracting State of which he is a nationalresident. 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
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, 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 7 contracts
Samples: www.hacienda.gob.es, www.hacienda.gob.es, 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 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 Agreementresident.
Appears in 6 contracts
Samples: 360.lexisnexis.at, www.nalog.ru, 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 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 3 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: Agreement, internationaltaxtreaty.com, 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 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 nationalresident. 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 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 6 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident resident, or, if his case comes under paragraph 1 of Article 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 AgreementConvention.
Appears in 6 contracts
Samples: Double Taxation Agreement, www.spenceclarke.com, www.incometaxindia.gov.in
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 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, santoslolowang.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 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 3 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 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: Agreement, www.sars.gov.za, 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 24, to that of the Contracting State of which he is 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 Agreement.
Appears in 5 contracts
Samples: Taxation Agreement With Turkey, Taxation Agreement, Taxation Agreement With Turkey
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 Agreementthis Convention.
Appears in 5 contracts
Samples: Treaty Series 2016, www.ujp.gov.mk, www.revenue.ie
MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident or a national of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 5 contracts
Samples: www.firs.gov.ng, www.orandcconsultants.com, aopsglobal-ng.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 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 5 contracts
Samples: internationaltaxtreaty.com, Agreement, Treaty Series 2011
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 that person 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 nationalresident. 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, 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 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 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 5 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 the remedies provided by the domestic law of those States, present his case address to the competent authority of the Contracting State of which he is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the Agreement.
Appears in 5 contracts
Samples: www.firs.gov.ng, www.orandcconsultants.com, aopsglobal-ng.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 this Agreement.
Appears in 5 contracts
Samples: Agreement, Double Taxation Avoidance Agreement, Agreement of 28th November
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 orresident, 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 5 contracts
Samples: into-sa.com, www.emta.ee, www.riigiteataja.ee
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 AgreementConvention, 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 2425, 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 AgreementConvention.
Appears in 4 contracts
Samples: South African Revenue, static.pmg.org.za, www.nyansa-africa.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 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 4 contracts
Samples: Ataf Model Agreement, Double Taxation Agreement, Model Tax 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 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 taxation not in accordance with the provisions of the AgreementConvention.
Appears in 4 contracts
Samples: www.emta.ee, www.emta.ee, auditors.am
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 4 contracts
Samples: firs.gov.ng, www.orandcconsultants.com, aopsglobal-ng.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 2 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.multi-count.com, cypruslaw.narod.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 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 States 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 4 contracts
Samples: Agreement, 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 that person in taxation not in accordance with the provisions of this AgreementConvention, 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 AgreementConvention.
Appears in 4 contracts
Samples: South African Revenue, www.hacienda.gob.es, static.pmg.org.za
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of the competent authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalresident. 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 4 contracts
Samples: www.legislation.gov.au, 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 address to the competent authority of the Contracting State of which he is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the Agreement.
Appears in 4 contracts
Samples: www.nalog.ru, Agreement, Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State considers that the actions of the competent authority of one or both of the Contracting States result or will result for him 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 case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalresident. 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, taxpolicy.ird.govt.nz, 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 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 nationalresident. 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 Agreementthis Convention.
Appears in 4 contracts
Samples: www.mof.gov.sa, zatca.gov.sa, www.mof.go.jp
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 the person may, irrespective of the remedies provided by the domestic law of those States, present his the case to the competent authority of the Contracting State of which he 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 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
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 4 contracts
Samples: 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 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 or national. The case must be presented within three years from of the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementthis Convention.
Appears in 4 contracts
Samples: franceintheus.org, franceintheus.org, www.swissbanking.ch
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 Agreementthis Convention.
Appears in 4 contracts
Samples: www.ris.bka.gv.at, archiv.llv.li, 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 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 the 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 3 contracts
Samples: www.econ-e.gr, workarea.et-gw.eu, www.dinamiki.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 orresident, 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: 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 24article 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.
Appears in 3 contracts
Samples: Double Taxation Agreement, Agreement, Tax 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 AgreementConvention, he that person may, irrespective of the remedies provided by the domestic law of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalresident. 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.mof.gov.sa, www.mof.gov.sa, gstc.gov.sa
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 AgreementConvention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his case address to the competent authority of the Contracting State of which he that person is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case application must be presented submitted within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementthis Convention.
Appears in 3 contracts
Samples: assets.publishing.service.gov.uk, relotax.co.il, www.treaty-accord.gc.ca
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 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 2426 of this Convention, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.
Appears in 3 contracts
Samples: www.emta.ee, internationaltaxtreaty.com, www.rahandusministeerium.ee
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 receipt of the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.
Appears in 3 contracts
Samples: internationaltaxtreaty.com, 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 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 Agreementthis Convention.
Appears in 3 contracts
Samples: Convention, internationaltaxtreaty.com, www.llv.li
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 of, 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 who is a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 nationalresident. 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: trungtamwto.vn, mof.gov.il, 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 that person in taxation not in accordance with the provisions of this AgreementConvention, he that person may, irrespective of the remedies provided by the domestic law laws of those States, present his case address to the competent authority of the Contracting State of which he that person is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the AgreementConvention.
Appears in 3 contracts
Samples: www.revenue.ie, internationaltaxtreaty.com, www.dfa.ie
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 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 (1) of Article 24(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.
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 the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.
Appears in 3 contracts
Samples: Taxation Avoidance Agreement, South African Revenue, 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 the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those StatesStates concerning taxes to which the Agreement applies, 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 3 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, www.aph.gov.au
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 or national. The case must be presented within three 5 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementthis Convention.
Appears in 3 contracts
Samples: www.unclefed.com, www.swissbanking.ch, www.irs.gov
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 3 contracts
Samples: Double Taxation Avoidance Agreement, internationaltaxtreaty.com, 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 that person in taxation not in accordance with the provisions of this AgreementConvention, 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 2425, 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 AgreementConvention.
Appears in 3 contracts
Samples: cacollege.co.za, cacollege.co.za, 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 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 AgreementConvention.
Appears in 3 contracts
Samples: www.finanze.it, www.studiocerbone.com, www.finanze.it
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 AgreementConvention, 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 AgreementConvention.
Appears in 3 contracts
Samples: internationaltaxtreaty.com, static.pmg.org.za, static.pmg.org.za
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 the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the either 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 nationalState. 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: www.aph.gov.au, treasury.gov.au, taxpolicy.crawford.anu.edu.au
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 Agreement.
Appears in 3 contracts
Samples: South African Revenue, Double Taxation Agreement, Tax 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 State 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 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 or which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Agreement.
Appears in 3 contracts
Samples: Agreement, Double Taxation Avoidance Agreement, phl.hasil.gov.my
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 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 2422 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, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person resident of one of the Contracting States considers that the actions of one or both of the Contracting States result or will result for him in taxation not laws in accordance with force in the provisions of this AgreementContracting States, he present may, irrespective of notwithstanding the remedies provided by the domestic law of those taxation laws in force in the 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 Agreementresident.
Appears in 3 contracts
Samples: Agreement, Cyprus Double Taxation Agreement, Cyprus 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 that person in taxation not in accordance with the provisions of this AgreementConvention, 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 AgreementConvention.
Appears in 3 contracts
Samples: South African Revenue, static.pmg.org.za, www.burs.org.bw
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person resident of one of the Contracting States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him in taxation not in accordance with 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 nationalresident. The case must be presented within three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the this Agreement.
Appears in 3 contracts
Samples: Agreement, www.legislation.gov.au, www.legislation.gov.au
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 nationalresident. 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 3 contracts
Samples: www.mof.gov.sa, zatca.gov.sa, 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, Convention he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2426 (Non-Discrimination), to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.
Appears in 3 contracts
Samples: s3-ap-northeast-1.amazonaws.com, www.rd.go.th, 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, Convention he may, irrespective of the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 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 Agreementthis Convention.
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 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 nationalresident. 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 2 contracts
Samples: www.qfc.qa, 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, and the time limits prescribed in such laws for presenting claims for refunds, 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 Agreementeither State.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. When a person 1. Where a person considers Considers that the actions of one measures taken by a Contracting State or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention taxation, he it may, irrespective of notwithstanding 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 state 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 2 contracts
Samples: 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, 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 2 contracts
Samples: internationaltaxtreaty.com, auditors.am
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 24article 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.
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 2 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, 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 24, to that of the Contracting State of which he is a nationalresident. 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: Agreement, www.nalog.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 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 2425, 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
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 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 2 contracts
Samples: Agreement, download1.fbr.gov.pk
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 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: mof.ge, 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 the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those StatesStates concerning taxes to which the Agreement applies, present his a case to the competent authority of the Contracting State of which he the person 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 nationalresident. 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 2 contracts
Samples: Agreement, www.legislation.gov.au
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 which gives rise to taxation not in accordance with the provisions of the this Agreement.
Appears in 2 contracts
Samples: Taxation Avoidance Agreement, Taxation Avoidance Agreement
