Mutual agreement procedure

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....provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of article 25, to that of the contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisi....

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....ot provided for in the Convention. 4. In the event the competent authorities reach an agreement referred to in paragraphs (2) and (3), taxes shall be imposed on such income, and refund or credit of taxes shall be allowed by the Contracting States in accordance with such agreement. It shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 5. The co....