Without prejudice to the remedies provided for by the national law of those States, if a State established in a Contracting State considers that the acts of one or both States Parties will result or will result in non-compliance under this Convention, it may submit its case to the competent authority of the State Party, in the event that it is domiciled by article 25, paragraph 1; to the State Party of which he is a national. This case must be submitted within three years of the initial notification of the appeal, which results in taxation that is not in accordance with the agreement. 4. . .