(1) Where a person considers that the actions of one or both
of the Contracting Parties result or will result for him in taxation
not in accordance with the provisions of this Agreement, he
may, irrespective of the remedies applying in the sovereign
territory of those Contracting Parties, present his case to the
competent authority of the Contracting Party of whose
sovereign territory he is a resident or, if his case comes under
paragraph 1 of Article 24, to that of the Contracting Party of
which he is a national. The case must be presented within three
years from the first notification of the action resulting in taxation
not in accordance with the provisions of the Agreement.
(2) The competent authority shall endeavour, if the objection
appears to it to be justified and if it is not itself able to arrive at
a satisfactory solution, to resolve the case by mutual agreement
with the competent authority of the other Contracting Party,
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 Parties.
(3) The competent authorities of the Contracting Parties 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 avoidance
of double taxation in cases not provided for in the Agreement.
(4) The competent authorities of the Contracting Parties may
communicate with each other directly, including through a joint
commission consisting of themselves or their representatives,
for the purpose of reaching an agreement in the sense of the
preceding paragraphs.
Citation to select or copy
Germany / North Macedonia; BGBl. 2010 II S. 1153; edition de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22; article 25; English; unreviewed source text, current applicability unverified; /editions/de-north-macedonia-2010-base/en/articles/article-25/
Disclaimers
Unreviewed machine transcription. Not a verified current-law consolidation or legal advice. Later changes may be missing.
Language switching retains source identifiers only. This is not reviewed legal or translational equivalence.
Page links are source references, not verified paragraph correspondence. Formatting and extraction errors may remain.
Noindex is not access control. This is a research preview, not a statement of authoritative or current law.
de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22
Text available here
Deutsch, English
Review
Unreviewed; qualified human review pending
Current applicability
Not verified
Gazette publication date
2010-10-22
Provenance
agent source-triage of pinned original; neither date is treaty entry/application
Signature date
2006-07-13
Edition notes and known limitations
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2006-07-13; consent law 2010-10-16; gazette publication 2010-10-22. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 29.11.2010, 16.01.2018. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Printed signature protocol retained separately and not merged into articles. Later amending protocol signed 2016-11-14, entered into force 2018-01-16, general application 2019-01-01; NOT included in this base source. Tax-specific application needs review. Source implementing law expressly publishes the treaty in the corrected version resulting from the exchange of notes dated 2008-07-23. Those corrections are incorporated by the official publication, not by this reader. The separately headed exchange-of-notes document is not printed in this retained PDF; do not mistake the law reference for a complete separate notes reader. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2016-11-14; entry into force: 2018-01-16; general application from: 2019-01-01; limit: Exact tax-specific application remains for protocol review.
This source supplies German and English versions. The signing clause also identifies Macedonian as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-north-macedonia-2010-base/. PDF page links identify pages, not verified paragraph correspondence.