Mutual Agreement Procedure

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..... 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 presented within three years .....

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..... ing 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 this Convention: [3] ARTICLE 16 OF T .....

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..... rdance 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 modification by the MLI, without regard to the taxable period to which the case .....

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