MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 47 contracts
Samples: www.mof.go.jp, www.mof.go.jp, www.mof.go.jp
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 20 contracts
Samples: impotsdirects.public.lu, www.llv.li, www.esteri.sm
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the Convention.
Appears in 19 contracts
Samples: Luxembourg Russia, data.parliament.uk, zatca.gov.sa
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the ConventionAgreement.
Appears in 17 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting Statethe 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 the this Convention.
Appears in 11 contracts
Samples: www.mof.gov.sa, www.mof.gov.sa, zatca.gov.sa
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting State. The State of which he is a 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 State of the Conventionwhich he is a national.
Appears in 9 contracts
Samples: www.nalog.ru, internationaltaxtreaty.com, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the ConventionAgreement.
Appears in 8 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the ConventionAgreement.
Appears in 8 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the ConventionAgreement.
Appears in 7 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 7 contracts
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the ConventionAgreement.
Appears in 7 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting Statethe 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 the Conventionthis Agreement.
Appears in 5 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 5 contracts
Samples: tap.mk.gov.lv, www.mof.go.jp, tap.mk.gov.lv
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the Convention.
Appears in 4 contracts
Samples: www.mof.gov.sa, www.mof.gov.sa, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law laws of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the Conventionthis Agreement.
Appears in 4 contracts
Samples: Taxation Avoidance Agreement, Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting State. The State of which he is a resident or, if his case must be presented within three years from the first notification comes under paragraph 1 of Article 22, to that of the action resulting in taxation not in accordance with the provisions Contracting State of the Conventionwhich he is a national.
Appears in 4 contracts
Samples: internationaltaxtreaty.com, www.foreignaffairs.irlgov.ie, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, States present his case to the competent authority of either the Contracting StateState 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 the this Convention.
Appears in 4 contracts
Samples: www.hacienda.gob.es, www.mof.gov.sa, zatca.gov.sa
MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 ConventionAgreement, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those Contracting States, present his case to the competent authority of either the Contracting StateState of which he is a resident. The 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 the ConventionAgreement.
Appears in 3 contracts
Samples: Agreement, Agreement, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Convention, he that person may, irrespective of the remedies provided by the domestic law of those Contracting States, present his the case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 3 contracts
Samples: opac.oireachtas.ie, www.revenue.ie, www.revenue.ie
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState of which he is a resident or, if his case comes under paragraph 1 of Article 23 of this Convention, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 3 contracts
Samples: mof.ge, www.rs.ge, internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective notwithstanding of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting Statethe 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 the Conventionthis Agreement.
Appears in 3 contracts
Samples: internationaltaxtreaty.com, Double Taxation Avoidance Agreement, phl.hasil.gov.my
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the Convention.
Appears in 2 contracts
Samples: zatca.gov.sa, www.mof.gov.sa
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState 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 the Convention.
Appears in 2 contracts
Samples: www.parlament.gv.at, www.parlament.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Convention, he the person may, irrespective of the remedies provided by the domestic law of those Contracting StatesStates concerning taxes to which this Convention applies, present his a case to the competent authority of either the Contracting StateState of which the person 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 the this Convention.
Appears in 2 contracts
Samples: www.survivefrance.com, www.aph.gov.au
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those Contracting States, present his the case to the competent authority of either the Contracting StateState of which 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 the ConventionAgreement.
Appears in 2 contracts
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting State. The State of which he is a resident or, if his case must be presented within three years from the first notification comes under paragraph (1) of Article 22 of this Convention, to that of the action resulting in taxation not in accordance with the provisions Contracting State of the Conventionwhich he is a national.
Appears in 2 contracts
Samples: www.legislation.gov.uk, www.sii.cl
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting State. The State of which he is a resident or, if his case must be presented within three years from the first notification comes under paragraph 1 of Article 23, to that of the action resulting in taxation not in accordance with the provisions Contracting State of the Conventionwhich he is a national.
Appears in 2 contracts
Samples: www.ris.bka.gv.at, www.parlament.gv.at
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law laws of those Contracting States, present his case to the competent authority of either Contracting State. The case must be presented within three (3) years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 2 contracts
Samples: Note, Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState of which he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States Countries result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting StatesCountries, present his case to the competent authority of either the Contracting StateCountry 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 the Convention.
Appears in 1 contract
Samples: internationaltaxtreaty.com
MUTUAL AGREEMENT PROCEDURE. 1. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this ConventionAgreement, he the person may, irrespective of the remedies provided by the domestic law of those Contracting StatesStates concerning taxes to which this Agreement applies, present his a case to the competent authority of either the Contracting StateState of which the person 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 the Conventionthis Agreement.
Appears in 1 contract
Samples: www.legislation.gov.au
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting State. State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 1 contract
Samples: soliq.uz
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either the Contracting StateState of which he is a resident or national. 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 the Convention.
Appears in 1 contract
Samples: www.incometaxindia.gov.in
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Conventionthis Agreement.
Appears in 1 contract
Samples: www.riigiteataja.ee
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Convention.
Appears in 1 contract
Samples: gstc.gov.sa
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this ConventionAgreement, he that person may, irrespective of the remedies provided by the domestic law of those Contracting States, present his a case to the competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 1 contract
Samples: Ataf Model Agreement
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those Contracting States, present his case to the competent authority of either the Contracting StateState of which he is a resident, or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention.
Appears in 1 contract
Samples: www.hacienda.gob.es
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him or her in taxation not in accordance with the provisions of this ConventionAgreement, he or she may, irrespective of the remedies provided by the domestic law of those Contracting States, present his or her case to the competent authority au- thority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the ConventionAgreement.
Appears in 1 contract
Samples: www.sif.admin.ch