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3.1.Lawsuits Filed and Requests for Conciliation Before Applying for the Mutual Agreement Procedure
3.3.7.Lawsuits Filed and Requests for Conciliation Before Applying According to Tax Model Agreements
3.3.7.1.OECD Model
If a taxpayer believes they have been or will be taxed in violation of the provisions…
If the taxpayer has filed lawsuits in the courts of both Contracting States for the…
On the other hand, in some countries, even if a court rules that taxation is in accordance…
3.3.6.Finalization of the Mutual Agreement Procedure Application According to the Provisions of the Tax Procedure Law
3.3.7.2.UN Model