Mutual agreement procedure

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Full Text of the Document

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....f those States, present his case in writing to the competent authority of the Contracting State of which he is a resident. The case must be presented within two years from the first notification of the action which gives rise to taxation not in accordance with the Agreement. 2. The competent authority referred to in paragraph 1 shall endeavour, if the objection appears to it to be justified and i....