Mutual Agreement Procedure

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..... on 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 to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. [The case must be presented within two years fr .....

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..... in accordance with the Agreement. Provided that the case has been presented within the time period specified in paragraph 1, any agreement reached shall be implemented notwithstanding any time limits in the 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 .....

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..... nce with paragraph 4 of Article 35 of the MLI, Article 16 of the MLI has effect with respect to this Agreement 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 Agreement prior to its modification by the MLI, without regard to the taxable period to which the case rela .....

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