Common use of MUTUAL AGREEMENT PROCEDURE Clause in Contracts

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions 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 law of those StatesParties, present his case to the competent authority of the Contracting State Party of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State Party of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementresident.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those States, present his the case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 23, to that of the Contracting State of which he the person is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalState. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with this Convention, the provisions of this Agreement, he 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 or, if his the case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he the person is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementthis Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him or her in taxation not in accordance with the provisions of this AgreementConvention, he or she may, irrespective of the remedies provided by the domestic law laws of those States, present his or her case to the competent authority of the Contracting State of which he or she is a resident or, if his or her case comes under paragraph 1 of Article 23article 25, to that of the Contracting State of which he or she is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those StatesStates concerning taxes to which the Agreement applies, 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 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those 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 2322, to that of the Contracting State of which he is a national. The This case must be presented within 3 three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where When a person considers 1. Considers that the actions of one measures taken by a Contracting State or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention taxation, he it may, irrespective of notwithstanding the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to 24 state that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person 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 law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementthis Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The This case must be presented within 3 five 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 AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law laws of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident orresident, or if his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the date of the first notification of the action resulting in taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person resident of one of the Contracting States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, Agreement he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident resident, or, if his case comes under paragraph 1 of Article 2326, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of notwithstanding the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article 2326 of this Agreement, to that of the Contracting State of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1 Where a person who is a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this AgreementConvention, he that person may, irrespective of the remedies provided by the domestic 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 that person is a resident or, if his the case comes under paragraph 1 of Article 2325 of this Convention, to that of the Contracting State of which he that person is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law of those StatesStates , present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324 , to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person who is a resident of a Contracting State considers that the actions of the competent authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2326, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 23, to that of the Contracting State of which he the person is a national. .. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 two years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 01 Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementthis Convention.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2325, to that of the Contracting State States of which he is a national. The case must be presented within 3 two years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementresident.

MUTUAL AGREEMENT PROCEDURE. Art. 25 1 -- Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23Art. 24, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person who is a resident of one of the Contracting States considers that the actions of the taxation authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of notwithstanding the remedies provided by the domestic law laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementaction.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 two years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person who is a resident of a Contracting State considers that the actions of the competent authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his the case to the competent authority of the Contracting State of which he that person is a resident or, if his the case comes under paragraph 1 of Article 23, to that of the Contracting State of which he that person is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. 1 Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of the remedies provided by the domestic law of those StatesStates concerning taxes to which this Agreement applies, 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 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. Where 1. If 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 AgreementAgreement , he may, irrespective of the remedies provided by the domestic law of those StatesStates , present his case to the competent authority of the authorities Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324 this Agreement , to that the competent authorities of the Contracting State , a national of which he it is a national. The case application must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementAgreement .

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his that case to the competent authority of the either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalState. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent competent, authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he be is a national. The case must be presented within 3 two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.Convention

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 23, to that of the Contracting State of which he the person is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person who is a resident of one of the Contracting States considers that the actions of the competent authority of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this Agreement, he the person may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalresident. The case must be presented within 3 years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of the this Agreement.

MUTUAL AGREEMENT PROCEDURE. (1 ) Where a person resident of a Contracting State considers that the actions of one taken by a Contracting State or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention imposition State, he may, irrespective of notwithstanding the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalnational . The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him that person in taxation not in accordance with the provisions of this Agreement, he that person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 23, to that of the Contracting State of which he the person is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of provisionsof the Agreement.

MUTUAL AGREEMENT PROCEDURE. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a national. The case must be presented within 3 two years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a national. The case must be presented within 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementresident.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which he is a nationalnatio- nal. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.the

MUTUAL AGREEMENT PROCEDURE. 1 -- Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23article 24, to that of the Contracting State of which he is a national. The case must be presented within 3 three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention.

MUTUAL AGREEMENT PROCEDURE. Where a (1) Any person who 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 Convention may, irrespective of notwithstanding the remedies provided by the domestic law laws of those States, present his case to the competent authority of the either Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 23, to that of the Contracting State of which he is a nationalState. The case Such presentation must be presented made within 3 years from the first notification period of time prescribed for the action resulting in taxation not in accordance with the provisions filing of the Agreement.a claim for credit or refund under Article