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 the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic law of those Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident or, if that person’s case comes under paragraph 1 of Article 22, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreementthis Agreement . 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities, through consultations, may develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 22article 23 of this Agreement, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement Agreement in the sense of the preceding paragraphsparagraphs of this article. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods, and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223 (Non-discrimination), to that of the Contracting State of which that person he is a national. The case must be presented within three (3) years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the Agreementthis 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 22article 26, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities shall through consultations develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 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 consisting of representatives of the competent authorities of the Contracting State.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the provisions of 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities shall through consultations develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. 5. The implementation of a mutual agreement should be made subject to the acceptance of such mutual agreement by the taxpayer, and to the taxpayer’s withdrawal of his suit at law concerning the points settled in the mutual agreement.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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 paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225 of this Agreement, to that of the Contracting State of which that 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 the 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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 paragraphsparagraphs of this Article.

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 the provisions of this Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that person he is a national. The case must be presented within three years from the first notification notificatian of the action resulting in taxation not in accordance with the provisions of the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the two Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. To facilitate an agreement, the preceding paragraphscompetent authorities of the two Contracting States may endeavour to reach an agreement through an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the 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 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 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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 paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, States present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, may develop appropriate procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable for reaching agreement, representatives of the competent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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.

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 Contracting States, States present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 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.

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 Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident or, if that person’s the case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the 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 a satisfactory solution, to resolve the case by mutual agreement 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 endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident or, if that person’s the case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly through consultations develop appropriate procedures, conditions, methods and techniques for the purpose of reaching an agreement in the sense implementation of the preceding paragraphsmutual agreement procedure provided for in this Article. In addition, a competent authority may devise appropriate procedures, conditions, methods and techniques to facilitate the above-mentioned actions and the implementation of the mutual 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 Contracting States, States present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 Contracting States, ‚ present a case to the competent authority of the Contracting State of which the person is a resident or, ‚ if that person’s the case comes under paragraph 1 of Article 22, 23‚ to that of the Contracting State of which that 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 the 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 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 the this Agreement. They may also consult together for the elimination avoidance of double taxation in cases not provided for in the this Agreement. (4. ) If the taxation of income in a Contracting State is effected by way of a withholding tax at source‚ and if this taxation is limited by the provisions of this Agreement‚ the application of this tax reduction or exemption shall be governed by the national law of that State in conjunction with the procedures agreed upon for this purpose between the competent authorities of the two 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 a satisfactory 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 Agreementagreement. 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 22, 24 to that of the Contracting State of which that 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 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 a satisfactory solution, to resolve the case by mutual agreement with the competent Agreement Beween the Government of the State of Qatar and the Government of Nepal For the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income 18 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods, and techniques for the implementation of the mutual 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 the 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 Contracting States, present a the case to the competent authority of the Contracting State of which the person is a resident or, if that the person’s case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 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 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement agreement, in the sense of the preceding paragraphs. The competent authorities through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2Convention. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4Convention. 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.

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 may, he may irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, or if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the this Agreement. 23. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the this Agreement. Any agreement reached shall be implemented notwithstanding any time limits limit in the domestic law of the Contracting States. 35. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the this Agreement. 47. 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. 8.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 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 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 endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the this Agreement.. FBR, Government of Pakistan 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods, and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly 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. The competent authorities, through 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 authority may devise appropriate unilateral procedures, conditions, methods and techniques to facilitate the above-mentioned bilateral actions and the implementation of the mutual 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 in taxation not in accordance with the provisions of this Agreement, that the person may, irrespective of the remedies provided by the domestic law of those Contracting States, present a the case to the competent authority of the Contracting State of which the person is a resident or, if that person’s the case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphsparagraphs of 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 provision of this AgreementConvention, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the 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 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 within five years from the domestic law date of the Contracting Statessuch an agreement. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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.

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 Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident or, if that person’s the case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly 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. The competent authorities, through 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 authority may devise appropriate unilateral procedures, conditions, methods and techniques to facilitate the above-mentioned bilateral actions and the implementation of the mutual agreement procedure.

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 notwithstanding the remedies provided by the domestic law taxation laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory 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 laws 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate communi cate with each other directly for the purpose purposes of reaching an agreement in the sense of the preceding paragraphs.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States State 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the provisions of 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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 paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting State may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a commission consisting of representatives of the competent authorities of the Contracting States.

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 Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident or, if that person’s the case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose purposes 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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, provided that the competent authority of the other Contracting State has received notification that such a case exists within three years from the end of the taxable year to which the case relates. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the this Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose purposes of reaching an agreement in the sense of the preceding paragraphs.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State States of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the provisions of this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the th 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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 paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 22, 24 to that of the Contracting State of which that 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 the 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that person he is a national. The case must be presented within three two years from the first notification issuance of the action resulting in taxation assessment not in accordance with the provisions of the 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 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, concerning their internal statute of limitation. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The provisions of this Agreement regarding the reduction or exemption from taxes on income in the Contracting States where 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States State 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 Contracting StatesState, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the 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 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. 3State. The competent authorities of the Contracting States State shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the this Agreement. 4. The competent authorities of the Contracting States State may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any within the 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach an 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, 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 the Agreement. They may also consult together each other for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article. 5. A Contracting State shall not, after the expiry of the time limits provided in its national laws and, in any case, after five years from the end of the taxable period in which the income connected has accrued, increase the tax base of a resident of either of the Contracting States. This paragraph shall not apply in the case of fraud, wilful default or neglect.

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 Convention he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s of it has case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that person he is a national. The This case must be presented within three years from the first notification Notification of the action resulting in giving rise to taxation not in accordance with the provisions of the 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 a satisfactory an apropriate solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of the 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 authoritys of the Contracting States states shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the AgreementConvention. They The may also consult together for the elimination of double taxation taxotion in cases not provided for in the AgreementConvention. 4. The competent conmpetent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding preceeding paragraphs. When it seems advisiable 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 State.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident orresident, or if that person’s his case comes under paragraph 1 of Article 22, to that of the Contracting State of which that 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 the 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 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 An agreement shall be reached within a period of two years after the question was formally raised by the competent authority and the agreement 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224 (Non- Discrimination), to that of the Contracting State of which that person he is a national. The case must be presented within three years from the first notification of the action resulting in which gives rise to taxation not in accordance with the provisions of the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article.

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 national laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the other Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of double 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a joint commission consisting of representatives of the competent authorities of the Contracting States. 1 [ ARTICLE 25

MUTUAL AGREEMENT PROCEDURE. 1. 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 (1) of Article 22(24), to that of the Contracting State of which that person he is a national. The me case must be presented within three years from the first notification nrst notincation of the action resulting in taxation not in accordance with the provisions of the Agreement. 2. The 2 - me competent authority shall endeavour, if the objection appears to it to be justified justined and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 3. The 3 - me competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties diaculties or doubts arising as to the interpretation or application of the Agreement. They mey may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The 4 - me 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 22, to 24,to that of the Contracting State of which that 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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. If for the reaching an agreement, it shall be advisable to organize a verbal exchange of opinions, such exchange of opinions may take place within the framework of the meeting of the 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that person he is a national. The case must be presented within three years from the first notification of the action actions resulting in taxation not in accordance with the provisions of the 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 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 An agreement shall be reached as soon as possible and 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person who is a resident of a Contacting State considers that the actions of the competent authorities 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident orresident, or if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the 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 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 this Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases incases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article.

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 notwithstanding the remedies provided by the domestic law national laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident resident, or, if that person’s his case comes under paragraph 1 of Article 2226, to that of the Contracting State of which that 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 the 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 a satisfactory 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4Convention. The competent authorities shall also, by mutual agreement, develop appropriate actions, methods and techniques to improve the exchange of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.information carried out under Article 28

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the application of the Agreement. In particular, they may consult together to endeavour to agree to the same allocation of income between associated enterprises mentioned in Article 9. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 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 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 endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods, and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 4. The competent authorities of the Contracting States may communicate with each other 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. The competent authorities through consultations may 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 authority may devise appropriate unilateral procedures, conditions, methods and techniques to facilitate the abovementioned bilateral actions and the implementation of the mutual 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 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 Contracting States, ‚ present a case to the competent authority of the Contracting State of which the person is a resident or, ‚ if that person’s the case comes under paragraph 1 of Article 22, 23‚ to that of the Contracting State of which that 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 the 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 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 the this Agreement. They may also consult together for the elimination avoidance of double taxation in cases not provided for in the this Agreement. 4. If the taxation of income in a Contracting State is effected by way of a withholding tax at source‚ and if this taxation is limited by the provisions of this Agreement‚ the application of this tax reduction or exemption shall be governed by the national law of that State in conjunction with the procedures agreed upon for this purpose between the competent authorities of the two 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement 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 any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose purposes of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through 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 authority may devise appropriate unilateral procedures, conditions, methods and techniques to facilitate the above-mentioned bilateral actions and the implementation of the mutual agreement procedure.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of оf 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphsforegoing articles of this Agreement. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person resident of a Contracting State 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law national laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 22, 23 to that of the other Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if if, it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases case not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person may, he may irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, or if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 l of Article 2224 of this Agreement, to that of the Contracting State of which that 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 the 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 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives, of the competent authorities of the Contracting States.

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 Contracting States, present a his case to the competent authority Competent Authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the this Agreement. Any agreement reached shall be implemented notwithstanding any within the 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultation, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the AgreementConvention. 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases case not provided for in the 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 paragraphsparagraphs of this Article. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities shall through consultations develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224 (Non-discrimination), to that of the Contracting State of which that 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 the AgreementConvention. 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 State 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2226, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting State.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 4. The competent authorities of the Contracting States or their representatives 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 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the 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 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 consisting 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224 (Non-discrimination), to that of the Contracting State of which that 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 the 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the AgreementConvention. 4. The competent authorities of the Contracting States may shall agree on administrative measures necessary to carry out the provisions of the Convention and particularly on the proofs to be furnished by residents of either Contracting State in order to benefit in the other State from the exemptions or reductions in tax provided for in the Convention. 5. The competent authorities of the Contracting States shall communicate directly with each other directly for the purpose of reaching an agreement in the sense application of the preceding paragraphsConvention.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting Contraction 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided provide for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the preceding paragraphscompetent authorities of the Contracting States may meet together for an oral exchange of opinions.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the 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 a satisfactory 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 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the this Agreement. 4. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of the Agreement 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. 5. 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.

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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the this Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. 5. The competent authorities of the Contracting States may by mutual agreement settle the mode of application of this Agreement and, especially, the requirements to which the residents of a Contracting State shall be subjected in order to obtain, in the other Contracting State, tax reliefs or exemptions on income referred to in Articles 10, 11 and 12, received from that other Contracting State.

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/her in taxation not in accordance with the provisions of this Agreement, that person he/she may, irrespective of the remedies provided by the domestic law national laws of those Contracting States, present a his/her case to the competent authority of the Contracting State of which the person he/she is a resident or, if that person’s his/her case comes under paragraph 1 of Article 22, 24 to that of the Contracting State of which that person he/she 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 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 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 StatesStates . 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate procedures, conditions, methods and techniques for the implementation of the mutual 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 provision of this Agreement, that person he may, irrespective of the remedies provided by the domestic law laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the this Agreement. Any agreement reached shall be implemented notwithstanding any 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement 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 laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2225 (Non-Discrimination), to that of the Contracting State of which that person he is a national. The case must be presented 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 the 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 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 the AgreementConvention. They may also consult together for the elimination of double taxation in cases not provided for in the Agreementthis 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, or if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the provisions of this 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the 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. The competent authorities shall through consultations develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under Under paragraph 1 of Article 2225, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly 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 Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 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 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities shall through consultations develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods, and techniques for the implementation of the mutual agreement procedure provided for in this Article.

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 such person in taxation not in accordance with the provisions of this Agreement, that such person may, irrespective of the remedies provided by the domestic law of those Contracting States, present a that person's case to the competent authority of the Contracting State of which the such person is a resident or, or if that person’s persons case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that such 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. Any agreement reached shall be implemented notwithstanding any 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2223, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods, and techniques for the implementation of the mutual 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 Agreement, that person he may, irrespective of the remedies provided by the domestic law laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the this Agreement. Any agreement reached shall be implemented notwithstanding any 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 laws of those Contracting States, present a his case to the competent authority of the Contracting State of which the person he is a resident or, if that person’s his case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that 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 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 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 endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs. The competent authorities , through consultations, may develop appropriate procedures, conditions, methods and techniques for the implementation of the mutual 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 Contracting States, present a case to the competent authority of the Contracting State of which the person is a resident or, if that person’s the case comes under paragraph 1 of Article 2224, to that of the Contracting State of which that the person 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 the Agreement. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the Agreement. 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 the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.