Mutual Agreement Procedure

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....n, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.] The following second sentence of paragraph 1 of Article 16 of the MLI applies and supersedes the provisions of this Convention:^[1] ARTICLE 16 OF THE MLI - MUTUAL AGREEMENT PROCEDURE The case must be present....

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....e domestic law of [the Contracting States]. 3. [Modified by second sentence of paragraph 3 of Article 16 of the MLI] [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 Convention.] The following second sentence of paragraph 3 of Article 16 of the MLI applies to t....

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....t regard to the taxable period to which the case relates. 2. In accordance with paragraph 4 of Article 35 of the MLI, Article 16 of the MLI has effect with respect to this Convention for a case presented to the competent authority of a Contracting State on or after 1 October 2019, except for cases that were not eligible to be presented as of that date under this Convention prior to its modif....