Mutual Agreement Procedure

If 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 the applicable Double Taxation Agreement, he may, irrespective of the remedies provided for by the domestic law of the Contracting States, present his case to the competent authority of the Contracting State of which he is a resident, in case that the applicable DTA does not provide for a right to submit a MAP request to both Contracting States. The Decision of the Governor of the Independent Authority for Public Revenue can be found  here.