Mutual Agreement Procedure

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....at the actions of one or both of the Contracting Jurisdictions result or will result for that person in taxation not in accordance with the provisions of the Covered Tax Agreement, irrespective of the remedies provided by the domestic law of those Contracting Jurisdictions, that person may present the case to the competent authority of the Contracting Jurisdiction of which the person is a resident or, if the case presented by that person comes under a provision of a Covered Tax Agreement relating to non-discrimination based on nationality, to that of the Contracting Jurisdiction of which that person is a national; and the competent authority of that Contracting Jurisdiction will implement a bilateral notification or consultation process wit....

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....he first notification of the action resulting in taxation not in accordance with the provisions of the Covered Tax Agreement. The article and paragraph number of each such provision is identified below. Listed Agreement Number Other Contracting Jurisdiction Provision 1 Albania Article 26(1), Second Sentence 2 Armenia Article 25(1), Second Sentence 3 Australia Article 25(1), Second Sentence 4 Austria Article 25(1), Second Sentence 5 Bangladesh Article 27(1), Second Sentence 6 Belarus Article 26(1), Second Sentence 8 Bhutan Article 24(1), Second Sentence 9 Botswana Article 26(1), Second Sentence 10 ....

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.... Article 25(1), Second Sentence 41 Latvia Article 25(1), Second Sentence 43 Lithuania Article 26(1), Second Sentence 44 Luxembourg Article 26(1), Second Sentence 45 Macedonia Article 25(1), second sentence 46 Malaysia Article 25(1), Second Sentence 47 Malta Article 25(1), second sentence 48 Mauritius Article 25(1), Second Sentence 49 Mexico Article 25(1), Second Sentence 50 Mongolia Article 26(1), Second Sentence 51 Montenegro Article 27(1), second sentence 52 Morocco Article 25(1), Second Sentence 53 Mozambique Article 25(1), Second Sentence 54 Myan....

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.... 80 Tanzania Article 25(1), Second Sentence 81 Thailand Article 25(1), Second Sentence 82 Trinidad and Tobago Article 25(1), Second Sentence 83 Turkey Article 25(2), Second Sentence 84 Turkmenistan Article 26(1), Second Sentence 85 Uganda Article 25(1), Second Sentence 86 Ukraine Article 26(1), second sentence 89 Uruguay Article 26(1), Second Sentence 90 USA Article 27(1), Second Sentence 91 Uzbekistan Article 27(1), Second Sentence 92 Vietnam Article 27(1), Second Sentence 93 Zambia Article 26(1), Second Sentence Notification of Listed Agreements Not Containing Exi....