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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within 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. 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State States of which he is a national. The This case must be presented within two years from the first 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 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. 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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. 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within 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. 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 consultationsconsultation, 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident orresident, or if his case comes under paragraph 1 of Article 2423, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 proof 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 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 ArticleConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 purposes of reaching an agreement in the sense view of application of the preceding paragraphsprovisions of this Convention. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under the paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The This case must be presented within two three years from the first notification of the action resulting in giving 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 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. 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 Agreementagreement. 4. The competent authorities of the Contracting States may communicate with each other directly for State shall agree on administrative measures necessary to carry out the purpose provisions of reaching an agreement the Agreement, particularly on the proofs to be furnished by residents of either Contracting State in order to benefit in the sense of other Contracting State from the preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods exemptions and techniques for the implementation of the mutual agreement procedure reductions in tax provided for in this Articlethe Agreement. When it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through a Commission consisting of representatives of the competent authorities of the Contracting States.

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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article 24(23), to that of the Contracting State of which he is a national. The case must be presented within two three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement. 2. 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. 3. 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. 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 State result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of notwithstanding the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of or which he is a national. The case must be presented within two 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 this 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 State 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 23 to that of the Contracting State of which he is a national. The case must be presented within 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. 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 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 24 to that of the Contracting State of which he is a national. The case must be presented within 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. 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 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 directly with each other directly for the purpose of reaching an agreement in the sense application of the preceding paragraphsConvention. The competent authoritiesIn particular, they shall, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this ArticleConvention.

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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 24 to that of the Contracting State of which he is a national. The case must be presented within 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. 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.

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 him in taxation not in accordance with the provisions of this Agreementagreement, he may, irrespective of may notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalresident. The case must be presented within two three years from the date of receipt of the first notification notice 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 above 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 national laws of the Contracting State. 3. The competent authorities of the Contracting States State 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 Agreement in the sense of the preceding paragraphs. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident orresident, or if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 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 ArticleConvention.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 shall agree on administrative measures necessary to carry out the provisions of the Agreement 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 Agreement. 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 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 ArticleAgreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State of which he is a national. The case must be presented within 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-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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his in the case comes under paragraph 1 of Article 24an individual, to that of the Contracting State of which he is a nationalcitizen. The case must be presented within two 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 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two three years from the receipt of the first notification of the action resulting in taxation not in accordance with the provisions of the Agreementthis Convention. 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at 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 AgreementConvention. 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 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him the person in taxation not in accordance with the provisions of this AgreementConvention, he the person may, irrespective of the remedies provided by the domestic law of those States, present his a case to the competent authority of the Contracting State of which he the person is a resident or, if his the case comes under paragraph 1 of Article 2423, to that of the Contracting State of which he the person is a national. The case must be presented within two 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. 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 resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two three (3) 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 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. 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.

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 him in taxation not in accordance with the provisions of this Agreementconvention, he may, irrespective of without prejudice to the remedies provided by the domestic law national laws of those States, present his case address to the competent authority of the Contracting State of which he is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case said application must be presented submitted within two 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 of the Contracting State shall endeavour, if the objection appears to it to be justified and if it it is not by 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 this 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 shall, when necessary, communicate with each other directly for the purpose of applying this Agreement and reaching an agreement in the sense of the preceding preceedings [sic] 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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 Agreement.Convention. Any 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 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that the competent authority of the Contracting State of which he is a national. The case must be presented within two 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. 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 cooperate for the elimination purpose of eliminating double taxation in cases not provided for referred to in the AgreementConvention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement as indicated in the sense of the preceding paragraphs. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2423, to that of the Contracting State of which he is a national. The case must be presented within two 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 f 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, 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 authoritiesIf an oral exchange of opinion appears necessary to facilitate this agreement, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation such exchange of views may take place within a Commission made up of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2422, to that of the Contracting State of which he is a national. The case must be presented within two 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 this Convention. Any agreement reached shall be implemented notwithstanding any time limits in the Agreementdomestic 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 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within 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. 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 authoritiesWhen it seems advisable in order to reach an agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law law- of those States, present his case to the competent authority of the Contracting State of which he is a resident or, . if his case comes under paragraph 1 of Article 24, 24 to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case ccase to the competent authority of the Contracting State of which he is a resident orresident, or if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 shall agree on administrative measures necessary to carry out the provisions of the Agreement. 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 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 ArticleAgreement.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques paragraphs or for the implementation purpose of giving effect to the provisions of the mutual agreement procedure provided for in this ArticleConvention.

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 him that person in taxation not in accordance with the provisions of this Agreement, he that person may, irrespective of the remedies provided pro- vided by the domestic law laws of those the Contracting States, present his a case to the competent authority au- thority of the Contracting State of which he the person is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a nationalresident. The case must be presented pre- sented within two three years from the first notification of the action resulting which results 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 justi- fied and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual mu- tual 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 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 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 Articlepara- graphs.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 authoritiesWhen it seems advisable for reaching agreement, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation representatives of the mutual agreement procedure provided competent authorities of the Contracting States may meet together for in this Articlean oral exchange of options.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law national laws of those States▇▇▇▇▇▇, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 24 to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 bilateral procedures, conditions, methods and techniques for the implementation of the mutual agreement procedure provided for in this Article.

MUTUAL AGREEMENT PROCEDURE. 1. Where When a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article (24, ) to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 methods, and techniques for the implementation of the mutual agreement procedure provided for in this Article.. 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, or if his case comes under paragraph 1 of Article 2426, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.Convention 2. The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at 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. 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent authorities of the Contracting States.

MUTUAL AGREEMENT PROCEDURE. 1. Where When a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 (1) of Article (24, ) to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, 24 to that of the Contracting State of which he is a national. The case must be presented within two 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 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. 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 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The This case must be presented within two years from the first 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 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 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 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. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 shall result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425 is applicable, to that of the Contracting State of which he is a national. The case must be presented within two three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention. 2. The That 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. 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 shall also consult together for the elimination of come to an agreement to try to avoid double taxation in cases not provided for in the Agreementthis Convention. 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 paragraphsparagraphs of this Article. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 State result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of notwithstanding the remedies provided by the domestic law laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of or which he is a national. The case must be presented within two 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 this 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 State 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.shall

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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 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. 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 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that the competent authority of the Contracting State of which he is a national. The case must be presented within two three years from the first 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 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. 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of without prejudice to the remedies provided by the domestic law national laws of those States, present his case address to the competent authority of the Contracting State of which he is a resident oran application in writing stating the grounds for claiming the revision of such taxation. To be admissible, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case said application must be presented submitted within 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 of the Contracting State shall endeavour, if the objection appears to it to be justified and if it is not by 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 this Agreement. 3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement Agreement any difficulties or doubts arising as to the interpretation or application of 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 shall when necessary communicate with each other directly for the purpose of applying this agreement and 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2422, to that the competent authority of the Contracting State of which he is a national. The case must be presented within two 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. 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 cooperate for the elimination purpose of eliminating double taxation in cases not provided for referred to in the AgreementConvention. 4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement as indicated in the sense foregoing 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 preceding paragraphs. The competent authorities, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation authorities of the mutual agreement procedure provided for in this ArticleContracting 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2422, to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement.the 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 The competent authorities 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.

MUTUAL AGREEMENT PROCEDURE. 1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention. 2. The That 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. 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 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 authoritiesIf it appears that such agreement may be facilitated by exchanges of oral impressions, such exchanges of impressions may be made through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within 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. 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 authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a Commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph Paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within two years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention. 2. The That 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. 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 AgreementConvention. 4. The competent authorities of the Contracting States may communicate with each other directly directly, including through a joint commission created by said authorities 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.

MUTUAL AGREEMENT PROCEDURE. 1. 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of notwithstanding the remedies provided by the domestic law national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident resident, or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two three years from the first notification of the action resulting in taxation not in accordance with the provisions of the AgreementConvention. 2. 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. 3. 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. 4.- The competent authorities of the Contracting States may communicate with each other directly for the purpose of or reaching an agreement in the sense of the preceding paragraphs. The competent authoritiesWhen it seems advisable in order to reach agreement to have an oral exchange of opinions, such exchange may take place through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation a commission consisting of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2424 is applicable, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 In particular, the competent authorities shall endeavor to reach an agreement for the elimination purposes of double taxation in cases not provided for in Article 9 of 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 by means of consultations, shall develop appropriate bilateral may work out unilateral procedures, conditions, methods and techniques appropriate for facilitating the implementation application of the Convention and the mutual agreement procedure provided for procedure. When it seems advisable in this Articleorder 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 him in taxation not in accordance with the provisions of this AgreementConvention, he may, irrespective of the remedies provided by the domestic law of those Contracting States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2424 is applicable, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 In addition, 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. The competent authoritiesWhen it is deemed that this agreement may be facilitated by means of personal contacts, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation exchange of viewpoints may take place within a committee comprised of representatives of the mutual agreement procedure provided for in this Articlecompetent 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, to that of the Contracting State of which he is a national. The case must be presented within 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, 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. 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 him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 2425, to that of the Contracting State of which he is a national. The case must be presented within two 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. 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 authoritiesWhen it seems advisable for reaching agreement, through consultations, shall develop appropriate bilateral procedures, conditions, methods and techniques for the implementation representatives of the mutual agreement procedure provided competent authorities of the Contracting State may meet together for in this Articlean oral exchange of opinions.