ARTICLE 27
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
Convention, 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
national. This case must be presented within three years of the
date of receipt of notice of the action which gives rise to
taxation not in accordance with the 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 Convention. Any agreement reached shall be
implemented notwithstanding any time limits or other procedural
limitations in the domestic law of the Contracting States.
3. The competent authorities of the Contracting States shall
endeavour to resolve by mutual agreement any difficulties or
doubts arising as to the interpretation or application of the
Convention. They may also consult together for the elimination
of double taxation in cases not provided for in the Convention.
4. The competent authorities of the Contracting States may
communicate with each other directly for the purpose of reaching
an agreement in the sense of the preceding paragraphs. The
competent authorities, through consultations, shall develop
appropriate bilateral procedures, conditions, methods and
techniques for the implementation of the mutual agreement
procedure provided for in this Article. In addition, a competent
authority may devise appropriate unilateral procedures,
conditions, methods and techniques to facilitate the above
mentioned bilateral actions and the implementation of the mutual
agreement procedure.