Common use of MUTUAL AGREEMENT PROCEDURE Clause in Contracts

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three 2 years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that the person in taxation not in accordance with this Agreement, that the person may, irrespective of the remedies provided by the domestic law of those StatesStates concerning taxes to which the Agreement applies, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement. 2. The competent authority shall endeavour, if the objection claim appears to it to be justified and if it is not itself able to arrive at an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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. 5. When it seems advisable in order to reach agreement to have an oral exchange For the purposes of opinions, such exchange may take place through a commission consisting paragraph 3 of representatives Article XXII (Consultation) of the competent authorities General Agreement on Trade in Services, the Contracting States agree that, notwithstanding that paragraph, any dispute between them as to whether a measure falls within the scope of this Agreement may be brought before the Council for Trade in Services, as provided by that paragraph, only with the consent of both Contracting States. Any doubt as to the interpretation of this paragraph shall be resolved under paragraph 3 of this Article or, failing agreement under that procedure, pursuant to any other procedure agreed to by both Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, 25 to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting StatesState. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 opinionsThe competent authorities, such exchange may take place through a commission consisting of representatives consultations, shall develop appropriate bilateral procedures, conditions, methods, and techniques for the implementation of the competent authorities of the Contracting Statesmutual agreement procedure provided for in this Article.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this 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 an appropriate 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that the person in taxation not in accordance with the provisions of this AgreementConvention, that the person may, irrespective of the remedies provided by the domestic law of those States, present a the case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 2324 (Non-discrimination), to of that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person is a national. The case must be presented within three years from the first notification period prescribed by the domestic law of the action resulting in taxation not in accordance with the provisions of this AgreementContracting States. 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits within the period prescribed in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person he is a national. The case must be presented within three years from the receipt of the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this AgreementConvention, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 joint commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this AgreementConvention, that person he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident resident, or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law laws of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, States present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits the statute of limitations in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 opinionsThe competent authorities, such exchange may take place through a commission consisting of representatives consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the competent authorities mutual agreement procedure provided for in the preceding paragraphs of the Contracting Statesthis Article.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with this AgreementConvention, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 joint commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this 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 an appropriate 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. Any : Provided that the case has been presented within the time period specified in paragraph 1, any agreement reached shall be implemented notwithstanding any time time-limits in the domestic law laws of the Contracting States. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in giving effect to the sense provisions of the preceding paragraphsAgreement. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2326, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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. 5. When it seems advisable If any difficulty or doubt arising as to the interpretation or application of the Convention cannot be resolved by the competent authorities in order a mutual agreement procedure pursuant to reach the preceding paragraphs of this Article within a period of two years after the question was raised, the case may, if both competent authorities and the taxpayer agree, be submitted for arbitration, provided that the taxpayer agrees in writing to be bound by the decision of the arbitration board. The decision of the arbitration board in a particular case shall be binding on both States with respect to that case. The procedure shall be established in mutual agreement to have an oral exchange of opinions, such exchange may take place through a commission consisting of representatives of between the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, States present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. (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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. (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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this Agreement, that person Convention he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person he is a national. The This case must be presented within three two years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this AgreementConvention. 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 an appropriate solution, to resolve the case by mutual agreement with the competent authority of the other Contracting contracting State, with a view to the avoidance of taxation which is not in accordance with the AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law national laws of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 advisable, in order to reach agreement agreement, to have an oral exchange of opinions, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions action of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 Agreementthis Convention. Any agreement reached shall be implemented notwithstanding any within the time limits in provided by the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 opinionsThe competent authorities, such exchange may take place through a commission consisting of representatives consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article. In addition, a competent authorities authority may devise appropriate unilateral procedures, conditions, methods and techniques to facilitate the above-mentioned bilateral actions and the implementation of the Contracting Statesmutual agreement procedure.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this 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 an appropriate 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23article 25, to that of the Contracting State of which the person 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 this 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 an appropriate a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, State with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement agreement. any difficulties or doubts arising as to the interpretation or application of this the Agreement. They may May also consult together each other for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where In the event that a person considers believes that the actions of one or both of the Contracting States result or will result for that person him or her in taxation that is not in accordance with the provisions of this AgreementConvention, that person he or she may, irrespective of the remedies provided for by the domestic law of those States, present a submit his case to the competent authority of the Contracting State of which the person he or she is a resident or, if the such case comes under paragraph 1 of Article 2324, to that the competent authority of the Contracting State of which the person he or she is a national. The case must be presented submitted within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it in case such competent authority is not itself able to arrive at an appropriate a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view in order to the avoidance of avoid taxation which is not in accordance with the Agreementthis Convention. Any agreement reached shall be implemented notwithstanding any time limits set forth in the domestic law Law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to everything in their power to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this AgreementConvention. They may also consult together for the elimination of reach an agreement in an attempt to eliminate double taxation in cases not provided for in this AgreementConvention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement agreements in the sense of the preceding paragraphsparagraphs of this Article. When In the event that it seems advisable in order to reach is believed that such agreement to have an oral exchange of opinionscan be facilitated by personal contacts, such exchange may of opinions can take place through within the scope of a commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this AgreementConvention, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2323 of this Agreement, to that of the Contracting State of which the person 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 this 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 an appropriate 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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 paragraphs of opinions, such exchange may take place through a commission consisting of representatives of the competent authorities of the Contracting Statesthis Article.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that the competent authority of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any The agreement reached shall be implemented notwithstanding any time limits in apply irrespective of the deadlines imposed by the domestic law laws of the Contracting States. 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 this Agreementthe Convention. They may also consult together cooperate for the elimination purpose of eliminating double taxation in cases not provided for referred to in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching arriving at an agreement in the sense of the preceding previous 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 one of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of these authorities or their representatives, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding the statute of limitations or any other time limits limit in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. 5. 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 The competent authorities may also agree on other forms of the Contracting Statesresolution when a mutual agreement cannot be reached.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any by the assessee in the time limits period provided in the domestic law laws of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this Agreement, that person Convention he may, irrespective of notwithstanding the remedies provided by the domestic law laws of those States, present a his case to the competent authority authorities of the Contracting State of which the person he is a resident resident, or, if the where his case comes under Article 25, paragraph 1 of Article 231, to that the competent authorities of the Contracting State of which the person he is a national. The Such case must be presented submitted within three years from the first notification of the action resulting which results in taxation not in accordance with the provisions of this AgreementConvention. 2. The competent authority authorities shall endeavour, if the objection appears to it them to be justified and if it is they are not itself themselves able to arrive at an appropriate solution, to resolve the case by mutual agreement with the competent authority authorities of the other Contracting Statestate, with a view to the avoidance of taxation which is not in accordance with the AgreementConvention. Any This mutual agreement reached procedure shall be implemented applied notwithstanding any the time limits in laid down by the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will may result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 Agreementthis Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 such agreement to have an oral exchange of opinions, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting Stateswithin ten years. (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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this the Agreement. (4. ) The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable . (5) Notwithstanding any other treaties of which the Contracting States are or may become parties, any dispute over a measure taken by a Contracting State involving a tax covered by Article 2 or, in order to reach agreement to have an oral exchange the case of opinionsnon-discrimination, such exchange may take place through any taxation measure taken by a commission consisting of representatives of Contracting State, including a dispute whether this Agreement applies, shall be settled only under the Agreement, unless the competent authorities of the Contracting StatesStates agree otherwise.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 joint commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 opinionsopinion, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. (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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. (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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three years from the first notification of the action regarded by such resident as resulting in taxation not in accordance with the provisions of this 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 an appropriate 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 provisions of this Agreement. Any agreement reached In the event the competent authorities reach an agreement, taxes shall be imposed, and refund or credit of taxes shall be allowed by the Contracting States in accordance with such agreement. It shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three 2 years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if it deems the objection appears to it to be justified and if it is not itself able unable to arrive at an appropriate a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to for the avoidance purpose of avoiding taxation which that is not in accordance with the AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of reach a mutual agreement in an attempt to eliminate double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate directly with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphsparagraphs of this Article. When In the event that it seems advisable in order to reach is believed that such agreement to have an oral can be facilitated by personal contacts, the exchange of opinions, such exchange may opinions can take place through within the scope of a commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this AgreementConvention, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement as indicated 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person he is a national. The case must be presented within three years from the receipt of the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 both of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 (1) of Article 2325, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (3. ) The competent authorities of the Contracting States shall shall. endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 (1) of Article 2325, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law national laws of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour Endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where If a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of this the Agreement. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with this AgreementConvention, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the that person is a resident or, if the case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 joint commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. (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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (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 this Agreementthe Convention. They may also consult together for the elimination avoidance of double taxation in cases not provided for in this Agreementthe Convention. (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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this Agreement, that person Convention he may, irrespective of notwithstanding the remedies provided by the domestic law laws of those States, present a his case to the competent authority authorities of the Contracting State of which the person he is a resident resident, or, if the where his case comes under relates to Article 26, paragraph 1 of Article 231, to that the competent authorities of the Contracting State of which the person he is a national. The Such case must be presented submitted within three years from of the first notification of the action resulting which results in taxation not in accordance with the provisions of this AgreementConvention. 2. The competent authority authorities shall endeavour, if the objection appears to it them to be justified and if it is they are not itself themselves able to arrive at an appropriate solution, to resolve the case by mutual agreement with the competent authority authorities of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the AgreementConvention. Any This mutual agreement reached procedure shall be implemented applied notwithstanding any the time limits in laid down by the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, 24 (Non-Discrimination) to that of the Contracting State of which the person he is a national. The case must be presented within three years from the first notification of the action regarded by such resident as resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 Agreementprovisions of this Convention. Any agreement reached shall be implemented notwithstanding Notwithstanding any time limits in the domestic law laws of the Contracting States, the solution so reached may be implemented within a period of six years from the date of presentation of the case by the resident to the relevant competent authority in accordance with paragraph 1 of this Article. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this AgreementConvention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting StatesState. 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 this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 Agreementthis Convention. Any agreement reached shall be implemented notwithstanding any time limits or other procedural limitations in the domestic law of the Contracting States. 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 this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this Agreement, that person he may, irrespective of the remedies provided by the domestic law national laws of those States, present a his case to the competent Competent authority of the Contracting State of which the person he is a resident orresident, or if the his case comes under paragraph 1 of 1, Article 2325, to that of the Contracting State of which the person 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 this Agreement. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding the statute of limitations or any other time limits limit in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an agreement in the sense of the preceding paragraphs. 5. 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 The competent authorities may also agree on other forms of the Contracting Statesresolution when a mutual agreement can not be reached.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this 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 an appropriate 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in limit of the domestic law of the tne Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this Agreementthe provisions of the treaty, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this AgreementConvention. 2. The competent authority shall endeavour, if the objection appears to it appears to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time time-limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 opinionsThe competent authorities, such exchange may take place through a commission consisting of representatives consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article. In addition, a competent authorities authority may devise appropriate unilateral procedures, conditions, methods and techniques to facilitate the above-mentioned bilateral actions and the implementation of the Contracting Statesmutual agreement procedure.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 (1) of Article 2324, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person of a Contracting State considers that the actions of one or both of the Contracting States result have resulted or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law laws of those States, present a his case in writing to the competent authority of the Contracting State of in which the person he is a resident orperson with permanent residency for consideration, setting forth the grounds for review of the decision concerning taxation. The application may be reviewed, if the case comes under paragraph 1 it is submitted within two years of Article 23, to that of the Contracting State of which the person is a national. The case must be presented within three years from the first notification of the action resulting which resulted in taxation not in accordance with the provisions of this AgreementConvention. 2. The competent authority referred to in paragraph 1 of this article shall endeavourendeavor, if it deems the objection appears to it application to be justified and or if it is not itself able to arrive at an appropriate 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 Agreementthis Convention. Any agreement reached shall be implemented notwithstanding irrespective of any time time-limits in the domestic law laws of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this AgreementConvention. 4. The competent authorities of the Contracting States may communicate establish direct contact with each other directly for one another with the purpose aim of reaching an agreement in applying the sense provisions 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 Statesthis Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this AgreementConvention, that person may, irrespective of the remedies provided by the domestic law of those States, present a case address to the competent authority of the Contracting State of which the that person is a resident or, if the that person's case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the that person is a national, an application in writing stating the grounds for claiming the revision of such taxation. The case To be admissible, the said application must be presented submitted within three two years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of this AgreementConvention. 2. The competent authority referred to in paragraph 1 shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting StatesConvention. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. In particular, the competent authorities of the Contracting States may consult together to endeavour to agree: (a) to the same attribution of profits to an enterprise of a Contracting State and to its permanent establishment situated in the other Contracting State; (b) to the same allocation of profits between associated enterprises as provided for in Article 9; (c) to the method of avoiding double taxation in the case of an estate or trust. 5. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in applying the sense provisions 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 StatesConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident orresident, or if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this AgreementConvention. (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 an appropriate 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 Agreementthis Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (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 this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this AgreementConvention. To that regard, it is not necessary to present a case according to paragraph 1. (4. ) The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this 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 an appropriate 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States Sta tes result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting StatesState. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three 3 years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreement.of 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement as indicated 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 (1) of Article 23, to 25 of that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate a satisfactory solution, to resolve the case by mutual agreement agree ment with the competent authority of the other Contracting State, State with a view to the avoidance of taxation which is not in accordance with the AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 opinionsThe competent authorities through consultation shall develop appropriate bilateral procedures, such exchange may take place through a commission consisting of representatives conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article. In addition, a competent authorities authority may devise appropriate unilateral procedures, conditions, methods and techniques to facilitate the abovementioned bilateral actions and the implementation of the Contracting Statesmutual agreement procedure.

MUTUAL AGREEMENT PROCEDURE. 1. Where When a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts disputes arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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. 5. When it seems advisable If after the procedures of paragraphs 1 to 4 any dispute arising as to the interpretation or application of the Convention in order a particular case cannot be resolved by the competent authorities of the Contracting States in a mutual agreement procedure, the case may, if both competent authorities agree, be resolved peacefully according to reach agreement to have an oral exchange of opinions, such exchange may take place through a commission consisting of representatives of any internationally accepted procedures. These procedures shall be established between the competent authorities of the Contracting States. 6. Information disclosed to persons or authorities in the course of resolving a dispute as meant in paragraph 5, shall by those persons or authorities be used only for that purpose.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23article 25, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time time-limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination purposes of eliminating double taxation in cases not provided for in this Agreementthe Convention and taking measures designed to prevent the incorrect application of the Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this AgreementConvention, that person he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 (1) of Article 2325, to that of the Contracting State of which the person he is a national. The This case must be presented within three years from the first notification of the action resulting in giving rise to taxation not in accordance with the provisions of this AgreementConvention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able about to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law national laws of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of or double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreement.State (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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident orresident, or if the his case comes under paragraph 1 (1) of Article 23article 26, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting StatesState. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 an agreement to have an oral exchange of opinionsoptions, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person he is a national. The case must be presented within three years from the first notification of the action resulting in taxation taxation, not in accordance with the provisions of this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law laws of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. 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 this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or of doubts arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, for the purpose of reaching an and 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provision of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or of doubts arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting StatesState. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person Agreement he may, irrespective of the remedies provided by the domestic law taxation laws of those States, States present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. The case An application must be presented in writing stating the grounds for claiming the revision of such taxation within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this 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 an appropriate 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in giving effect to the sense provisions of the preceding paragraphsthis Agreement. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 meeting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. (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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. (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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one the other Contracting State or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law national laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this AgreementConvention. 2. The That competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate a satisfactory solution, to resolve the case question 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic national law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination avoidance of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation in-terpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 paragraphsparagraphs of this Article. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States, or of their representatives.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 (1) of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 provision of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreement.the Convention 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 agreements to have an oral exchange of opinions, such exchange may take place through a commission Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits or other procedural limitations in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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. 5. 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 The competent authorities may also agree on other forms of the Contracting Statesresolution when a mutual agreement cannot be reached.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law laws of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2327, to that of the Contracting State of which the person he is a national. The case must be presented within three years from the receipt of the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law laws of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this AgreementConvention, that person may, irrespective of the remedies provided by the domestic law of those States, present a case to the competent authority of the Contracting State of which the person is a resident or, if the case comes under paragraph 1 of Article 2322, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this the Agreement. 4. The provisions of this Agreement regarding the reduction or exemption from taxes on income in the Contracting State here it arises shall be applied in accordance with the laws of that State and the procedures to be agreed by the competent authorities of both Contracting States. 5. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2326, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate a satisfactory solution, to resolve the case by mutual agreement with the competent competant authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the AgreementConvention. Any agreement reached shall be implemented by the competent authorities notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. The case must be presented within three two years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented applied notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate comunicate 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 Commission consisting of representatives of the competent authorities of the Contracting States. 5. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2327, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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. 5. 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 The competent authorities of the Contracting StatesStates may by mutual agreement settle the mode of application of the Convention and especially, the requirements to which the residents of a Contracting State shall be subjected in order to obtain, in the other Contracting State, the tax reductions or exemptions and other advantages provided for by the Convention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph Paragraph 1 of Article 2324, to that of the Contracting State of which the person 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 this Agreementthe Convention. 2. The Such competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law Law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 In the event that personal contacts appear suitable to reach agreement to have an oral exchange of opinionsagreement, such exchange of opinions may take place through via a joint commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. (1. ) Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 (1) of Article 2324, to that of the Contracting State of which the person 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 this 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 an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. (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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2324, to that of the Contracting State of which the person he is a national. The case must be presented within three 2 years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The competent authorities of the Contracting States shall endeavour endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law laws of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of authorities of one or both of the Contracting States territories result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law in force of those Statesterritories, present a his case to the competent authority of administering the Contracting State territory of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State territory of which the person he is a nationalnational under the laws in force of that territory. 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 this 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 an appropriate a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting Stateterritory, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting Statesterritories. 3. The competent authorities of the Contracting States territories shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this the Agreement. 4. The competent authorities of the Contracting States territories 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this Agreementthe Convention. 2. The competent authority shall endeavourendeavor, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting StatesConvention. 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 this Agreementthe Convention. In particular, they may consult together for the purpose of reaching an agreement on the allocation of income in cases referred to in Article 9. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention. 4. In the event the competent authorities reach an agreement referred to in paragraphs 2 and 3, taxes shall be imposed on such income, and refund or credit of taxes shall be allowed by the Contracting States in accordance with such agreement. 5. 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23, to that of the Contracting State of which the person 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 this the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it it is not itself able to arrive at an appropriate 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. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreement. the Agreement They may also consult together for the elimination of double taxation in cases not provided for in this 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 Commission consisting of representatives of the competent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 23article 24, to that of the Contracting State of which the person 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 this 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 an appropriate 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission consisting of themselves or their representatives, 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 opinionsThe competent authorities, such exchange may take place through a commission consisting of representatives consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the competent authorities of the Contracting Statesmutual agreement procedure provided for in this Article.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for that person him in taxation not in accordance with the provisions of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if the his case comes under paragraph 1 of Article 2325, to that of the Contracting State of which the person 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 this Agreementthe Convention. 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 an appropriate 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 AgreementConvention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 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 this Agreementthe Convention. They may also consult together for the elimination of double taxation in cases not provided for in this Agreementthe Convention and to take measures destined to prevent incorrect use of the Convention. 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 Commission consisting of representatives of the competent authorities of the Contracting States.