Common use of MUTUAL AGREEMENT PROCEDURE Clause in Contracts

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a 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 AgreementConvention.

MUTUAL 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 2324, 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.

MUTUAL 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 2324, 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.

MUTUAL 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 2324, 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.

MUTUAL 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 either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a 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 AgreementConvention.

MUTUAL 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 2322, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, 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.

MUTUAL 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 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, 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.

MUTUAL 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 2326, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2325, 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.

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 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him 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 2322, 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.

MUTUAL 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 either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a 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.

MUTUAL 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 23, 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 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 2324, 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.

MUTUAL 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 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.

MUTUAL 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 2324, 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.

MUTUAL 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 2325, 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.

MUTUAL 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 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.

MUTUAL 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324 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.

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 2326, 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.

MUTUAL 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 2325, 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.

MUTUAL 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 23, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the 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 23, 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.

MUTUAL 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 2324, 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.

MUTUAL 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 either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a 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 Agreementthis Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, 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.

MUTUAL 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 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324 of this Agreement, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. 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 23, 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.

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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2322, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, 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.

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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, 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 which gives rise to taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, 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.

MUTUAL 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 23, to that of the Contracting State of which he that person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States 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 2324, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of the 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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions 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 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.

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 l of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 23, 24 to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, 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.

MUTUAL 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 2325 of this Agreement, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers 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 2324, 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.

MUTUAL 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States 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 23, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of measures adopted by one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2325, 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.

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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324 (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.

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 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him 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 23, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Agreement.

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 2324, 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.

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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States 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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2325 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.

MUTUAL 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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, 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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2325, to that of the Contracting State of which he is a national. The case must be presented within three years from the receipt of the first notification of the action resulting in taxation not in accordance with the provisions of the this 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, 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, or if his case comes under paragraph 1 of Article 2324, 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.

MUTUAL 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 2324, 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.

MUTUAL 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 2325, 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.

MUTUAL 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 2324, to that of the Contracting State of which he is a national. The case must be presented within three years one year from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this 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 2324, 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.

MUTUAL 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 23, 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.

MUTUAL 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 2324, 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.

MUTUAL 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 2324, 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.

MUTUAL 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 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 notificatian of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States 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 23, 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.

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 2324, 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.

MUTUAL 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, 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 2322, 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.

MUTUAL 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 2324, 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.

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

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case address to the competent authority of the Contracting State of which he is a resident orresident, if his case comes under paragraph 1 of Article 23, or to that of the Contracting State of which he is a national. The national if his case must be presented within three years from comes under paragraph 1 of Article 22, an application in writing stating the first notification grounds for claiming the revision of the action resulting in taxation not in accordance with the provisions of the Agreementsuch taxation.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him 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 2325, 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.

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 2324, 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.

MUTUAL 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 either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalState. 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 this 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 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 2325, 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 taxation, not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this AgreementConvention, he that person may, irrespective of the remedies provided by the domestic law of those States, present his the case to the competent authority of the Contracting State of which he that person is a resident or, if his that person’s case comes under paragraph 1 of Article 2324, 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.