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of <h1>Residents Can Challenge Tax Actions Under Article 25 of Double Taxation Avoidance Agreement Within Three Years</h1> Article 25 of the Double Taxation Avoidance Agreement (DTAA) between two Contracting States outlines the mutual agreement procedure. It allows residents of either state to present a case to their local competent authority if they believe taxation actions are inconsistent with the agreement. This must be done within three years of the first notification of such action. The competent authorities of both states are tasked with resolving the issue, even if it requires cooperation beyond national time limits. They are also responsible for addressing any difficulties or doubts regarding the agreement's application and may communicate directly to implement its provisions.
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