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of <h1>Residents Can Challenge Unfair Taxation Under DTAA Article 25; Resolve Issues via Mutual Agreement Procedure Within 3 Years</h1> Article 25 of the Double Taxation Avoidance Agreement (DTAA) between Contracting States provides a Mutual Agreement Procedure for residents facing taxation not in accordance with the Convention. Affected residents can present their case to the competent authority of their state within three years of notice. If justified, the competent authority will seek resolution with the other state's authority to avoid improper taxation, regardless of national time limits. The authorities also aim to resolve interpretative issues and eliminate double taxation through mutual agreement, which may involve direct communication or a Commission for oral discussions.
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