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" States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority... "
Internal Revenue Cumulative Bulletin - Page 406
by United States. Internal Revenue Service - 1977
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Internal Revenue Bulletin: Cumulative bulletin, Issue 2

United States. Internal Revenue Service - 1968 - 1034 pages
...residents of that firstmentioned State, is or may be subjected. AsTicr.E 25 MUTUAL AGREEMENT PBOCEDURE (1) Where a resident of a Contracting State considers...Contracting States result or will result for him in taxation net in accordance with this Convention, toe may, notwithstanding the remedies provided by the national...
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Model tax conventions

United States. Congress. Joint Committee on Internal Revenue Taxation - 1962 - 724 pages
...owned in that other Contracting State. 31 II ANNEX E ARTICLE ON MUTUAL AGREEMENT PROCEDURE Article XXV 1. Where a resident of a Contracting State considers...Contracting States result or will result for him in taxation net in accordance with this Convention, he may, notwithstanding the ranedles provided by the national...
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Internal Revenue Cumulative Bulletin

United States. Internal Revenue Service - 1976 - 624 pages
...of the Contracting States considers that the action of one or both of the Contracting States results or will result for him in taxation not in accordance...notwithstanding the remedies provided by the national laws of the Contracting States, present his case to the competent authority of the Contracting State of which...
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Internal Revenue Cumulative Bulletin, Issue 2

United States. Internal Revenue Service - 1979 - 644 pages
...of the Contracting States considers that the action of one or both of the Contracting States results or will result for him in taxation not in accordance...notwithstanding the remedies provided by the national laws of the Contracting States, present his case to the competent authority of the Contracting State of which...
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Joint Venture Agreements in Romania: Background for Implementation, Volume 57

Pompiliu Verzariu, Jay A. Burgess - 1977 - 110 pages
...of the Contracting States considers that the action of one or both of the Contracting States results or will result for him in taxation not in accordance...notwithstanding the remedies provided by the national laws of the Contracting States, present his case to the competent authority of the Contracting State of which...
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Tax Treaties: Hearing Before the Committee on Foreign Relations, United ...

United States. Congress. Senate. Committee on Foreign Relations - 1982 - 532 pages
...apply to Article 25. Article 26. MUTUAL AGREEMENT PROCEDURE Paragraph l provides that a person who considers that the actions of one or both of the Contracting...result, for him in taxation not in accordance with the Convention, he may present his case to the competent authority of the State of which the person...
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United States Congressional Serial Set

1987 - 948 pages
...taxes which are the subject of this Agreement. ARTICLE 25 MUTUAL AGREEMENT PROCEDURE 1. Where a person considers that the actions of one or both of the Contracting...result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law...
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European Yearbook

P. Drillien, Euye - 1984 - 892 pages
...apply to taxes of every kind and description. Article 11. Mutual agreement procedure 1 . Where a person considers that the actions of one or both of the Contracting...result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic laws...
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Congressional Serial Set

1992 - 858 pages
...subdivision or local authority thereof. - 43 Article 26 Mutual Agreencnt Procedure 1. '.Iherc a person considers that the actions of one or both of the Contracting States result or will result for hin ii taxation not in accordance with the provisions of this Cor vent 1 on, he nay, irrespective of...
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Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries

Daniel Sandler - 1998 - 326 pages
...Where a resident of a Contracting State considers that the actions of one or both Contracting States will result for him in taxation not in accordance...of those States, present his case to the competent authorities of the Contracting State in which he is a resident. 214 relieve double taxation except...
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