Resolution of Difficulties. The Competent Authorities of the Parties shall resolve, to the extent possible, any difficulties which arise in interpreting or applying this Agreement according to its spirit and fundamental principles.
Resolution of Difficulties. 1. Disagreements arising in connection with the application of this Agreement shall, as far as possible, be resolved by mutual agreement between the competent authorities of the Parties.
2. If any such disagreement has not been resolved within a period of six months, either Party may submit the matter to binding arbitration by an arbitral body whose composition and procedure shall be agreed upon by the Parties.
3. Paragraph 2 does not apply in relation to the application of Part II of this Agreement.
Resolution of Difficulties. 1. The Competent Authorities of the Parties shall resolve, to the extent possible, any difficulties which may arise in interpreting or applying this Agreement according to its spirit and fundamental principles.
2. The Parties shall consult promptly at the request of either Party concerning matters which have been resolved by the Competent Authorities in accordance with paragraph 1.
3. Any dispute between the Parties concerning the interpretation of this Agreement which has not been resolved or settled by consultation in accordance with paragraph 1 or 2 shall, at the request of either Party, be submitted to arbitration.
4. Unless the Parties mutually determine otherwise, the arbitral tribunal shall consist of three arbitrators, of whom each Party shall appoint one and the two arbitrators so appointed shall appoint a third who shall act as President; provided that if the two arbitrators fail to agree, the President of the International Court of Justice shall be requested to appoint the President.
5. The arbitrators shall determine their own procedures.
6. The decision of the arbitrators shall be final and binding.
7. Unless the Parties otherwise agree, the place of arbitration shall be in the territory of the Party which did not raise the matter in dispute.
Resolution of Difficulties. 1. The Competent Authorities of the Contracting States shall resolve, to the extent possible, any difficulties which arise in interpreting or applying this Agreement according to its spirit and fundamental principles.
2. If a solution cannot be found in this way, the matter in dispute shall be referred to arbitration which shall settle it within the meaning and spirit of this Agreement. The Contracting States shall provide for the composition and procedure of that arbitration by mutual agreement.
3. Paragraph 2 does not apply in relation to the application of Part II of this Agreement.
Resolution of Difficulties. The tax authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreement. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place directly between representatives of the tax authorities of the Contracting States.
Resolution of Difficulties. 1. The competent authorities of the Parties shall resolve, to the extent possible, any difficulties which arise in interpreting this Agreement according to its spirit and fundamental principles.
2. The Parties shall consult promptly at the request of either Party concerning difficulties which have not been resolved by the competent authorities in accordance with paragraph 1.
3. If the difficulty has not been resolved within six months following the consultation prescribed in paragraph 2 it may be submitted at the request of one or both Parties to an arbitration commission.
4. Unless the Parties mutually determine otherwise, the Commission shall consist of 3 arbitrators of whom each Party shall appoint one and the two arbitrators so appointed shall appoint a third who shall act as President; provided that if any Party fails to appoint an arbitrator within 30 days from the date on which one or both Parties has requested the difficulty be submitted to an arbitration commission, or in the event of a disagreement over the appointment of the President of such commission, the President of the international Court of Justice shall be requested by one or both Parties to appoint the arbitrator or as the case may be, the President of the arbitration commission.
5. The commission shall determine its own procedures.
6. The decision of the commission shall be final and binding.
Resolution of Difficulties o Paragraph 1: The Competent Authority shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Agreement. In order to reach agreement an oral exchange of opinions can take place directly between representatives of the tax authorities of the Contracting States.
Resolution of Difficulties. 1. The competent authorities of the Parties shall resolve, to the extent possible, any difficulties which arise in interpreting this Agreement according to its spirit and fundamental principles.
2. If within 6 months from the date the matter first arose the difficulty cannot be resolved, it shall be submitted at the request of one or both the Parties to an arbitration commission.
3. Unless the Parties mutually determine otherwise, the Commission shall consist of 3 arbitrators of whom each Party shall appoint one and the two arbitrators so appointed shall appoint a third who shall act as President; pro vided that, in default of agreement, the President of the International Court of Justice shall be requested to appoint the President.
4. The commission shall determine its own procedures.
5. The decision of the commission shall be final and binding.
Resolution of Difficulties. 1. The competent authorities and the competent institutions of the Contracting States shall resolve, to the extent possible, any difficulties which arise in interpreting or applying this Agreement according to fundamental principles and to the spirit of this Agreement.
2. The Contracting States shall consult promptly at the request of either Contracting State concerning matters which have not been resolved by the competent authorities or the competent institutions in accordance with paragraph 1.
3. Any dispute between the Contracting States concerning the interpretation of this Agreement which has not been resolved or settled by consultation in accordance with paragraph 1 or 2 shall, at the request of either Contracting State, be submitted to arbitration by an arbitral tribunal.
4. The decision of the arbitral tribunal shall be final and binding.
Resolution of Difficulties. 1. The competent authorities of the Parties shall resolve, to the extent possible, any difficulties which arise in interpreting or applying this Agreement according to its spirit and fundamental principles.
2. The Parties shall consult promptly at the request of either Party concerning matters which have not been resolved by the competent authorities in accordance with paragraph 1.
3. Any dispute between the Parties concerning the interpretation of this Agreement which has not been resolved or settled by consultation in accordance with paragraph 1 or 2 shall, at the request of either Party, be submitted to arbitration by an arbitral tribunal.
4. Unless the Parties mutually determine otherwise, the arbitral tribunal shall consist of three arbitrators, of whom each Party shall appoint one and the two arbitrators so appointed shall appoint a third who shall act as president; provided that if either Party fails to appoint its arbitrator or if the two arbitrators fail to agree, the competent authority of the other Party shall invite the President of the International Court of Justice to appoint the arbitrator of the first Party or the two appointed arbitrators shall invite the President of the International Court of Justice to appoint the president of the arbitral tribunal.
5. If the President of the International Court of Justice is a citizen of either Party, the function of appointment shall be transferred to the Vice- president or the next most senior member of the Court who is not a citizen of either Party.
6. The arbitral tribunal shall determine its own procedures, but it shall reach its decisions by a majority of votes.
7. The decision of the arbitral tribunal shall be final and binding.
