Mutual Agreement Procedure

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....or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of 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 no....

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....t. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. 4. The competent authorities of the Contracting States may consult together for the elimination of double taxation in cases not provided for in the Agreement.     FOOTNOTES:- ....