MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the 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 States, present his case to the competent authority of the State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this 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 ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of this Conventionthe Agreement.
Appears in 8 contracts
MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this ConventionAgreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Conventionthe Agreement.
Appears in 7 contracts
MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the 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 States, present his case to the competent authority of the State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this ConventionAgreement.
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 States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this 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 Convention, he may, irrespective of the remedies provided by the domestic law of those States, States present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Convention.
Appears in 4 contracts
Samples: www.hacienda.gob.es, 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 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 States, present his the case to the competent authority of the State of which he is a residenteither 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 this 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 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 States, present his case to the competent authority of the State of which he is a residentresident or, if his case comes under paragraph 1 of Article 24, to that of the State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Convention.
Appears in 3 contracts
Samples: Agreement, www.incometaxindia.gov.in, 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 States, present his case to the competent authority of the State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this ConventionAgreement.
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 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 States, present his case to the competent authority of the 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 previsions of this Convention.
Appears in 2 contracts
Samples: 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 States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the 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 StatesStates concerning taxes to which this Convention applies, present his a case to the competent authority of the Contracting State of which he the person is a resident. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of 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 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 States, present his case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this the 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 States, present his case to the competent authority of the Contracting State of which he is a residentresident 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 this Convention.
Appears in 1 contract
Samples: www.incometaxindia.gov.in