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 - Էջ 406United States. Internal Revenue Service - 1977Ամբողջությամբ դիտվող - Այս գրքի մասին
| Helmut Loukota, Albert J. Rädler, Josef Schuch, Franz Wassermeyer, Gerald Toifl, Christoph Urtz - 1998 - 266 էջ
...apply to taxes of every kind and description. 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... | |
| United Nations Staff - 2002 - 564 էջ
...this Article, the term "taxation" means taxes which are the subject of this Agreement. 476 Article 25 Mutual Agreement Procedure 1. Where a resident of...State considers that the actions of one or both of the Contacting States result or will result for him in taxation not in accordance with the provisions of... | |
| World Trade Organization - 2002 - 576 էջ
...of this provision that the procedure is set in motion at the request of an individual taxpayer who "considers that the actions of one or both of the...Contracting States result or will result for him in taxation which is not in accordance with the provisions of" the convention. In other words, the purpose is to... | |
| Michelle Markham - 2005 - 360 էջ
...Model Tax Convention 1995, which deals with the mutual agreement procedure provides: (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... | |
| Joseph Isenbergh - 2006 - 806 էջ
...authority" provision in article 25, under the heading "Mutual Agreement Procedure": 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... | |
| Zvi Daniel Altman - 2005 - 498 էջ
...Convention, supra note 3, which reads as follows: "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... | |
| 2001 - 596 էջ
...provision of this Convention, the Convention does not apply in relation to that income. Article 27. Mutual Agreement Procedure (1) Where a resident of...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... | |
| 416 էջ
...provisions of this Article shall apply to the taxes which are the subject of this Convention. ARTICLE 26 Mutual agreement procedure (1) Where a resident of...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... | |
| 460 էջ
...this article shall apply to all taxes of every kind and description. Article 25 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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