Double Taxation Agreement

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MUTUAL AGREEMENT PROCEDURE
ARTICLE 25

121	Scope.
122.	Mutual agreement procedure is not a substitute to remedies under the domestic laws.
122.1	Presentation of a case.
122.2	Presentation of a case.
123	Competent authority - How resolves the case.
123.1	Competent authority - Endeavours to resolve the case.
123.2	Implementation of the agreement - Time limit in the national laws is not bar.
124.	Difficulties or doubts of general nature - Resolution of.
125.	Procedure for resolving difficulties.