Mutual agreement procedure

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Full Text of the Document

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.... laws of those Contracting States present the case to the competent authority of the Contracting State of which he is a resident. The case must be presented within three years from the date of the assessment or of the withholding of tax at the source, whichever is later. (2) The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to a....