A G R E E M E N T BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MOLDOVA AND THE SWISS FEDERAL COUNCIL

A G R E E M E N T BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MOLDOVA AND THE SWISS FEDERAL COUNCIL FOR THE AVOIDANCE OF DOUBLE TAXATION

A G R E E M E N T BETWEEN THE GOVERNMENT OF THE REPUBLIC OF MOLDOVA AND THE SWISS FEDERAL COUNCIL FOR THE AVOIDANCE OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND ON CAPITAL


Inkraft seit 2000-08-22

Artikel 25
MUTUAL AGREEMENT PROCEDURE

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 Agreement, he may, irrespective of the remedies provided by the domestic  law of those States, present his case to the competent authority of the Contracting  State of which he is a resident or, if his case comes under paragraph 1 of Article 24,  to that of 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 Agreement. 


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 Contracting  State, with a view to the avoidance of taxation which is not in accordance with the  Agreement.


3. The competent authorities of the Contracting States shall endeavour to  resolve by mutual agreement any difficulties or doubts arising as to the interpretation  or application of the Agreement. They may also consult together for the elimination  of double taxation in cases not provided for in the Agreement. 


4. The competent authorities of the Contracting States may communicate with  each other directly for the purpose of reaching an agreement in the sense of the  preceding paragraphs. When it seems advisable in order to reach agreement to have  an oral exchange of opinions, such exchange may take place through a Commission  consisting of representatives of the competent authorities of the Contracting States.