Common use of MUTUAL AGREEMENT PROCEDURE Clause in Contracts

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws law of those Contracting States, present his case in writing to the competent authority of the Contracting State of which he is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a one of the Contracting State 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 national laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three 3 years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of may notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 provision of this Agreement, he may, irrespective of the remedies provided by the domestic laws of those Contracting StatesState, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The This 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State considers that the actions of one or both the competent authority of the a Contracting States State 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 national laws of those the Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three four years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The If his case must be presented within three years from the first notification comes under paragraph 1 of Article 24, to that of the action resulting in taxation not in accordance with the provisions Contracting State of this Agreementwhich he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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, Convention he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The This case must be presented within three two years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a one of the Contracting State 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 national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 saving the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The This case must be presented within three years from of the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident 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 this the Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this 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 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 national laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three 4 years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a one of the Contracting State 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 for the person not in accordance with the provisions of this Agreement, he the person may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case claim must be presented lodged within three two years from the first notification date on which the tax was notified or withheld at the source or within two years of the action resulting in taxation not in accordance with the provisions entry into force of this AgreementConvention, whichever is the later.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 notwithstanding the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The resident or, if his case must be presented within three years from the first notification comes under paragraph (1) of the action resulting in taxation not in accordance with the provisions Article 26 of this Agreement, to that Contracting State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 laws 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. The case must be presented within three years from the first notification time limits provided for in the domestic law of the action resulting in taxation not in accordance with the provisions of this AgreementContracting State.

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 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 laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is 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 in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic laws of those Contracting States, present his case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 25 to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contracting State Party considers that the actions of the competent authority 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 laws law of those Contracting StatesParties, present his case to the competent authority of the Contracting State of Party which he the person is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person who is a resident of a one of the Contracting State States considers that the actions of the taxation 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 national laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective independently of the any remedies provided by for under the domestic laws of those Contracting States, present submit his case to the competent authority of the Contracting State of which he is a resident. The case must be presented submitted within three years from after the first notification of the action resulting in taxation which is not in accordance with the provisions of this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a one of the Contracting State 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, Agreement he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident 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 this the Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case in writing to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 22, to that of the Contracting State of which he is a national. The This 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 this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this 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 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 national laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three 3 years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The This case must be presented within three years from of the first notification date of receipt of notice of the action resulting in which gives rise to taxation not in accordance with the provisions of this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 laws law of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a residentresident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person is a national. The case must be presented within three years from the first notification period prescribed by the domestic law of the action resulting in taxation not in accordance with the provisions of this AgreementContracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 laws 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. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 without prejudice to the remedies provided by the domestic national laws of those Contracting States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming the revision of such taxation. The case To be admissible, the said 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 this Agreement.

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 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 laws law of those Contracting StatesStates concerning taxes to which this Convention applies, present his a case to the competent authority of the Contracting State of which he that person is a resident. The resident or, if the case must be presented within three years from the first notification comes under paragraph 1 of Article 25 of this Convention, to that of the action resulting in taxation not in accordance with the provisions Contracting State of this Agreementwhich that person is a national.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 national laws of those Contracting States, present his case to the competent Competent authority of the Contracting State of which he is a resident, or if his case comes under paragraph (1), Article 25, to the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a Contracting State contracting state considers that the actions of one or both of the Contracting States contracting states result or will result for him in taxation not in accordance with the provisions of this Agreementagreement, he may, irrespective of notwithstanding the remedies provided by the domestic laws law of those Contracting Statesstates, present his case to the competent authority of the Contracting State contracting state of which he is a resident. The resident or, if his case must be presented within three years from the first notification comes under paragraph (1) of the action resulting in taxation not in accordance with the provisions Article 26 of this Agreementagreement, to that contracting state of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting these States, present his case to the competent authority of the Contracting State of which he is a resident. The case claim must be presented lodged within three two years from the first notification date of the action resulting in taxation not in accordance with assessment or of the provisions withholding of this Agreementtax at the source whichever is the later.

MUTUAL AGREEMENT PROCEDURE. - 1. ) Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case claim must be presented lodged within three two years from the first notification date of the action resulting in taxation not in accordance with assessment or of the provisions withholding of this Agreementtax at the source whichever is the later.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a one of the Contracting State States considers that the actions of one or both of the Contracting States result or will result for him in double taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic laws of those Contracting States, present his case in writing to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting these States, present his case to the competent authority of the Contracting State of which he is a resident. The case claim must be presented lodged within three two years from the first notification date of the action resulting in taxation not in accordance with assessment or of the provisions withholding of this Agreementtax at the source, whichever is later.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting States of which he is a national. The This 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 this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will may 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 national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one the other 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, he may, irrespective of the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident 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 this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. 1. 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 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 laws law of those Contracting StatesStates concerning taxes to which this Convention applies, present his a case to the competent authority of the Contracting State of which he that person is a resident. The resident or, if the case must be presented within three years from the first notification comes under paragraph 1 of Article 25 of this Convention, to that of the action resulting in taxation not in accordance with the provisions Contracting State of this Agreementwhich that person is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented to the other Contracting State within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 pro- vided by the domestic laws of those the Contracting States, present his a case to the competent authority au- thority of the Contracting State of which he the person is a resident. The case must be presented pre- sented within three years from the first notification of the action resulting which results in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a one of the Contracting State States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The This 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 this Agreementaction.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or if his case comes under paragraph 1 of Article 26, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 laws law' of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The This case must be presented within three years from of the first notification of the action resulting in which gives rise to the taxation not in accordance with the provisions of this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 laws of those the Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three years from the first notification of the action resulting which results in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 11 . Where When a resident of a Contracting State considers that the actions of one or both taken by any of the Contracting States result or will result for him in to involve the resident taxation not in accordance with the provisions of this Agreementtitle , he may, irrespective of notwithstanding the remedies provided by the domestic laws law of those Contracting States, present his case to consideration of the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementwhere reside .

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a one of the Contracting State States, considers that the actions of one or both of the Contracting States result 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 taxation laws of those in force in the Contracting States, States present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 notwithstanding the remedies provided by the domestic taxation laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The resident or, if his case must be presented within three years from the first notification comes under paragraph 1 of Article 24, to that of the action resulting in taxation not in accordance with the provisions Contracting States of this Agreementwhich he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 without prejudice of the remedies provided by the domestic national laws of those Contracting States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming the revision of such taxation. The case To be admissible, the 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. ) Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case claim must be presented lodged within three two years from the first notification date of the action resulting in taxation not in accordance with assessment or of the provisions withholding of this Agreementtax at the source whichever is the later.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 double taxation not in accordance with the provisions of prohibited by this AgreementConvention, he may, irrespective independently of the remedies provided by the domestic national laws of those Contracting States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming revision of his taxation. The case said application must be presented within three submitted before the expiry of a period of two years from the first notification of liability to or the action resulting in taxation not in accordance with deduction at source of the provisions of this Agreementsecond charge to tax.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 laws law of those Contracting States, present his case address to the competent authority of the Contracting State of which he that person is a resident. The case must be presented within three years from resident 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 this Agreementsuch taxation.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a Contracting State contracting state considers that the actions of one or both of the Contracting States contracting states result or will result for him in taxation not in accordance with the provisions of this Agreementagreement, he may, irrespective of the remedies provided by the domestic laws law of those Contracting Statesstates, present his case to the competent authority of the Contracting State contracting state of which he is a resident. The resident or, if his case must be presented within three years from the first notification comes under paragraph (1) of Article 25 of this agreement, to that of the action resulting in taxation not in accordance with the provisions contracting state of this Agreementwhich he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the date of such action resulting in taxation not in accordance with or the provisions latest of this Agreementsuch actions as the case may be.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 saving the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming the revisions of such taxation. The This 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case claim must be presented lodged within three two years from the first notification date of the action resulting in taxation not in accordance with assessment or of the provisions withholding of this Agreementtax at the source whichever is the later.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The resident or, if his case must be presented within three years from the first notification comes under paragraph 1 of the action resulting in taxation not in accordance with the provisions Article 26 of this Agreement, to that of the Contracting State of which he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result results 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 national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the date of such action resulting in taxation not in accordance with or the provisions latest of this Agreementsuch actions as the case may be.

MUTUAL AGREEMENT PROCEDURE. 1. (1 ) Where a resident of a Contracting State considers that the actions of one 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 imposition State, he may, irrespective of notwithstanding the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentnational . The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will may result for him in taxation for him/her not in accordance compliance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his his/her case to the competent authority of the Contracting State of which he he/she is a resident. The case must shall be presented within three years from according to the first notification of terms set forth in the action resulting in taxation not in accordance with the provisions of this Agreementrespective domestic law.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where 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 notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph (1) of Article 23, to that of the Contracting State of which he is a national. The This 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. 1 Where a person who is a resident of a one of the Contracting State 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 acoordance with the provisions of this Agreement, he the person may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case a cose to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three 3 years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will may result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic laws of those Contracting these States, present his case to the competent authority of the Contracting State of which he is a resident. The case must This proceeding may not be presented within three used after a period of 2 years from the first notification of the action resulting in taxation not in accordance with tax or collection of the provisions of this Agreementtax at source has elapsed.

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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he that person is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this Agreementthe Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must claim has to be presented lodged within three a period of two years from the first date notification of the action resulting tax lastly imposed or in taxation not in accordance with the provisions case of this Agreementwitholding at source from the date of the payment of the income subject to such withholding.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. 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 this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of without prejudice to the remedies provided by the domestic laws of those Contracting States, present his case submit a request in writing for a revision of such taxation to the competent authority of the Contracting State of which he is a resident. The case To be admissible, such request must be presented submitted within three two years from the first after notification of the action measure resulting in taxation which is not in accordance with the provisions of this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a one of the Contracting State States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic laws of those Contracting States, present his case in writing to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where Were a 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, Convention he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. 1 Where a person who is a resident of a one of the Contracting State 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 national laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three 3 years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a resident of a one of the Contracting State States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The This 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 this Agreementaction.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 without prejudice to the remedies provided by the domestic national laws of those Contracting States, present his case address to the competent authority of the Contracting State of which he is a residentresident an application in writing stating the grounds for claiming the revision of such taxation. The case To be admissible, the said application must be presented submitted within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a 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 national laws of those Contracting StatesState, present his case to the competent authority of the Contracting State of which he is a resident. The case claim must be presented lodged within three two years from froms the first notification date the assessment or of the action resulting in taxation not in accordance with withholding of tax at the provisions of this Agreementsource whichever is the later.

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 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 national laws of those Contracting States, present his a case to the competent authority of the Contracting State of which he the person is a resident. 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 this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a resident of a Contracting State 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 national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 23 to that of the other 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 this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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, Convention he may, irrespective of notwithstanding the remedies provided by the domestic laws of those Contracting States, present his case to the competent authority authorities of the Contracting State of which he is a resident, or, where his case relates to Article 26, paragraph 1, to the competent authorities of the Contracting State of which he is a national. The Such case must be presented submitted within three years from of the first notification of the action resulting which results in taxation not in accordance with the provisions of this AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident 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 this the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of the remedies provided by the domestic laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident. The resident or, if his case must be presented within three years from the first notification comes under paragraph (1) of Article 27 of this Convention, to that of the action resulting in taxation not in accordance with the provisions Contracting State of this Agreementwhich he is a national.

MUTUAL AGREEMENT PROCEDURE. 1. Where 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 AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic national laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is national. The This 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 this AgreementConvention.