 | P. Drillien, Euye - 1984 - 892 lapas
...competent authority of either Contracting State. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention. 2. The competent authority, if the objection appears to it to be justified... | |
 | 1990 - 84 lapas
...present Finnish treaty. It is similar, however, to a provision in the US-Canada income tax treaty. The OECD model treaty includes a three-year limitation...that a problem exists. Under the proposed treaty, no refund can be required unless there is some reason to believe that a refund case will exist before... | |
 | United States. Congress. Joint Committee on Taxation - 1990 - 70 lapas
...he is a resident or national. In such an instance, the case must be presented within five years from the first notification of the action resulting in taxation not in accordance with the provision of the proposed treaty. For this purpose, provision 18 of the proposed protocol specifies... | |
 | 1990 - 78 lapas
...to the country of which they are residents or nationals within three years of the receipt of notice of the action resulting in taxation not in accordance with the treaty. Although no time limit is imposed in the US model treaty, the three-year limit is consistent with the... | |
 | 1992 - 858 lapas
...Contracting State of which he is a resident or national. The case must be presented within five years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention. 2. The competent authority shall endeavor, if the objection appears to... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1993 - 66 lapas
...rules, a case must be presented for consideration to a competent authority within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the proposed treaty. The US model does not specify any time limit for presentation of... | |
 | United States. Congress. Senate. Committee on Foreign Relations - 1995 - 46 lapas
...26), a case must be presented for consideration to a competent authority within three years from the notification of the action resulting in taxation not in accordance with the provisions of the proposed treaty. The US model does not specify any time limit for presentation of... | |
 | Pasquale Pistone - 2002 - 424 lapas
...the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Convention. 2. The competent authority shall endeavour, if the objection appears... | |
 | Michelle Markham - 2005 - 360 lapas
...the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Convention. (2) The competent authority shall endeavour, if the objection appears... | |
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Convention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other... 
