Jurisdiction for proceedings under mutual tax assistance: each State's measures are litigated only before its own competent body. Proceedings under the Convention must be brought only before the appropriate body of the State whose measures are challenged; proceedings by the applicant State concerning recovery (existence or amount of the tax claim or the enforcement instrument) must be brought before the applicant State's competent body and, if instituted, the applicant State shall inform the requested State which shall suspend its procedure pending the decision. The requested State shall take conservatory measures if requested, may be informed by interested persons and shall consult with the applicant State as necessary; final decisions must be notified and their implications for the assistance request explained.
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Jurisdiction for proceedings under mutual tax assistance: each State's measures are litigated only before its own competent body.
Proceedings under the Convention must be brought only before the appropriate body of the State whose measures are challenged; proceedings by the applicant State concerning recovery (existence or amount of the tax claim or the enforcement instrument) must be brought before the applicant State's competent body and, if instituted, the applicant State shall inform the requested State which shall suspend its procedure pending the decision. The requested State shall take conservatory measures if requested, may be informed by interested persons and shall consult with the applicant State as necessary; final decisions must be notified and their implications for the assistance request explained.
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