Mutual Agreement Procedure

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Full Text of the Document

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.... of those States, present his case to the competent authority of the Contracting State of which he is a resident. The claim must be lodged within two years from the date of the assessment or of the withholding of tax at the source, whichever is the later. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at an appro....