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3.3.4.2.UN Model
After an application for the mutual agreement procedure is submitted, if the competent…
We had mentioned that the only difference between Article 25’s Alternative A and…
In the UN Model, the Contracting States are also obligated to make efforts toward…
In light of these explanations, it would be appropriate to state that, in the context…
To facilitate a better understanding of the subject, it would be suitable to refer…
Figure 8.Prevention and Resolution of Tax Disputes. (Source: United Nations Handbook…
Figure 9.Five Steps of MAP Under Article 25/1. (Source: United Nations Handbook on…
3.3.4.1.OECD Model
3.3.5.Finalization of the Mutual Agreement Procedure Application According to Bilateral Tax Treaties
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