Article XII
1. Paragraph 1 of Article 25 (Mutual agreement procedure), as renumbered, of the Convention shall be deleted and replaced by the following:
"1. Where a person considers that the actions of one or both of the Contracting 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 of either Contracting Stale. 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. In paragraph 3 of Article 25 (Mutual agreement procedure), as renumbered, of the Convention the word "problems" shall be deleted and replaced by the words "difficulties or doubts".
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Protocol Amending the Convention Between the Government of the Russian Federation and the Government of the Kingdom of Sweden... |