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 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, 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 date of 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 this Agreement, 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, 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 date of receipt of the first notification notice 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 in writing to the competent authority of the Contracting State of which he is a resident, 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 two years from the date of 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 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, or if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The This case must be presented within three five years from of the date of the first notification 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 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, 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 date of 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 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, or if his case comes under paragraph 1 of Article 2523, to that of the Contracting State States of which he is a national. The This case must be presented within three two years from the date of 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 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, 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 date of 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 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, 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 date of 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 State result or will result for him in taxation not in accordance with the 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, 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 date of 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 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, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The This case must be presented within three years from the date 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 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, or if his case comes under paragraph 1 of Article 2522, to that of the Contracting State of which he is a national. The This case must be presented within three years from the date of 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 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, or if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The This case must be presented within three two years from the date of 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 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, 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 date 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 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, 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 date of 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 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, 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 date of 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 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, or if his case comes under paragraph 1 of Article 25, 25 to that of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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, 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 four years from the date 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 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, 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 submitted within three years from the date of 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 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, or if . If his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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, or if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The This case must be presented within three years from the date 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 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, or if his case comes under paragraph 1 of Article 25, 24 to that of the Contracting State of which he is a national. The case must be presented within three two years from the date of 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 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, 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 date 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 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, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three two years from the date of 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 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, or if his the case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he the person is a national. The case must be presented within three years from the date period prescribed by the domestic law of the first notification 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, 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 date of 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, 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 date of 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 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, 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 date of 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 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 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, 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 date 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 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, 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 date of 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 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, 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 claim must be presented lodged within three two years from the date on which the tax was notified or withheld at the source or within two years of the first notification 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 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 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, 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 4 years from the date 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 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, 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 3 years from the date of 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 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 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, 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 date 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 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, or if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The This case must be presented within three years from of the date of the first notification 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 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 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, 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 3 years from the date 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 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 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, 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 date 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 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, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three (3) years from the date of 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 laws law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a residentresident or, or if his case comes under paragraph 1 (1) of Article 2526 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 date of 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 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 residentresident or, or if his the case comes under paragraph 1 of Article 2525 of this Convention, to that of the Contracting State of which he that person is a national. The case must be presented within three years from the date of 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 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, 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 date of 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 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, 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 date time limits provided for in the domestic law of the first notification of the action resulting in taxation not in accordance with the provisions of this AgreementContracting State.

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 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 residentresident or, or if his the case comes under paragraph 1 of Article 2525 of this Convention, to that of the Contracting State of which he that person is a national. The case must be presented within three years from the date of 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 result, or will result result, for him in taxation not in accordance with 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, 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 date of 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 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, 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 date 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 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, or if his case comes under paragraph 1 . This proceeding may not be used after a period of Article 25, to that of the Contracting State of which he is a national. The case must be presented within three 2 years from the date of 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 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 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, or if his case comes under paragraph 1 (1) of Article 2523, to that of the Contracting State of which he is a national. The This case must be presented within three years from the date 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 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 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, 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 date of 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 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, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three two years from the date of 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 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, or if his case comes under paragraph 1 resident an application in writing stating the grounds for claiming the revisions of Article 25, to that of the Contracting State of which he is a nationalsuch taxation. The This case must be presented within three two years from the date of 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 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, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State of which he is a national. The case must be presented within three years from the date of the first notification of the action resulting in taxation not in accordance with the provisions of this the 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 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, 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 date of 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 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, 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 3 years from the date 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 these 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 25, to that of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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, 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 date of 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, resident or if his case comes under paragraph 1 of Article 2526, to that of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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 residentresident or, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State States of which he is a national. The case must be presented within three years from the date of 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 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, 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 date of 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 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. To be admissible, 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 said application must be presented submitted within three two years from the date of 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 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, or if his case comes under paragraph 1 (1) of Article 2527 of this Convention, to that of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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, 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 claim must be presented lodged within three two years from the date of the first notification 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 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, 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 date of 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 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, 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 two years from the date of 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 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, or if his case comes under paragraph 1 of Article 2524, to that of the Contracting State States of which he is a national. The This case must be presented within three years from the date of 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 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. To be admissible, 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 said application must be presented submitted within three two years from the date of 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 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 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, 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 date of 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 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 residentresident or, or if his case comes under paragraph 1 (1) of Article 2525 of this agreement, to that of the Contracting State contracting state of which he is a national. The case must be presented within three years from the date of 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 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, or if his case comes under paragraph 1 of Article 2523, to that the competent authority of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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 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 25, to that of the Contracting State of which he is a national. The case must be presented within three two years from the date of 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 action of one or both of the Contracting States result or will result for from him in taxation not in accordance with this Agreement, he may, irrespective with the competent of the remedies provided by the domestic laws contracting state of those Contracting States, present his case to the competent authority of the Contracting State which of which he is a resident, 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 date of the first notification of the action resulting in taxation not in accordance with the provisions of this 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 taxation not in accordance with this Agreement, he may, irrespective of to involve 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, 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 date of the first notification of the action resulting in resident taxation not in accordance with the provisions of this Agreementtitle , may, notwithstanding the remedies provided by the domestic law of those States, present his case to consideration of the competent authority of the Contracting State where reside .

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 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, 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 claim must be presented lodged within three two years from the date of the first notification 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 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, 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 five years from the date of 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 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, 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 date of 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 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, 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 date of 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 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, or if his case comes under paragraph 1 (1) of Article 2525 of this Convention, to that of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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, 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 date of 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 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, or if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The This case must be presented within three years from the date of the first notification 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 result, or will result 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, 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 date of the first notification of the action resulting in giving rise to 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 may result for him in taxation not in accordance with 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, 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 date of 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 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. To be admissible, 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 such request must be presented submitted within three two years from the date of 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 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 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, 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 date of 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 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, or if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The This case must be presented within three years from the date of 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 action of one or both of the Contracting States result or will result for him in taxation not in accordance with 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, or if his case comes under paragraph 1 of Article 25, 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 date of 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 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, 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 claim must be presented lodged within three two years from the date of the first notification 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 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, 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 date of 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 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 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 if or, where his case comes under paragraph 1 of Article 25, paragraph 1, to that the competent authorities of the Contracting State of which he is a national. The Such case must be presented submitted within three years from the date 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 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, or if his case comes under paragraph 1 . The claim has to be lodged within a period of Article 25, to that two years from the date notification of the Contracting State tax lastly imposed or in the case of which he is a national. The case must be presented within three years witholding at source from the date of the first notification payment of the action resulting in taxation not in accordance with the provisions of this Agreementincome 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 double taxation not in accordance with 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 resident, or if resident an application in writing stating the grounds for claiming revision of his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a nationaltaxation. The case said application must be presented within three submitted before the expiry of a period of two years from the date notification of liability to or the deduction at source of the first notification of the action resulting in taxation not in accordance with 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 in taxation not in accordance with 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, 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 date of the first notification of the action resulting person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, address to the competent authority of the Contracting State of which that person is a resident an application in writing stating the grounds for claiming the revision of such taxation.

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, or if his case comes under paragraph 1 of Article 2523, to that of the Contracting State of which he is a national. The case must be presented within three years from the date of 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 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, 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 two years from the date of 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 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, 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 of the date of such action or the first notification latest of such actions as the action resulting in taxation not in accordance with the provisions of this Agreementcase 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 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, 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 to the other Contracting State within three two years from the date of 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 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 residentresident or, or if his case comes under paragraph 1 (1) of Article 2526 of this agreement, to that of the Contracting State contracting state of which he is a national. The case must be presented within three years from the date of 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 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, or if his case comes under paragraph 1 of Article 2524, to that of the other Contracting State of which he is a national. The case must be presented within three two years from the date of 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 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 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, or if his case comes under paragraph 1 of Article 25, to that of the Contracting State of which he is a national. The This case must be presented within three two years from the date of 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 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, 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 2 years from the date of 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 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, 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 claim must be presented lodged within three two years from the date of the first notification 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 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 this Agreement, he may, irrespective of without prejudice to the remedies provided by the domestic national laws of those Contracting States, present make written application for a review of the said taxation, indicating his case reasons, to the competent authority of the Contracting State of which he is a resident. In order to be admissible, 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 such application must be presented submitted within three two years from the date of notification or of deduction at the first notification source of the action resulting in taxation not in accordance with the provisions of this Agreementsecond taxation.

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 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, 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 claim must be presented lodged within three two years from the date of the first notification assessment or of the action resulting in taxation not in accordance with withholding of tax at the provisions of this Agreementsource, whichever is later.