Source paragraph 1
(1) Where a person considers that the actions of one or both of the Contracting States result or will result for that person in taxation not in accordance with the provisions of this Agreement‚ that person may‚ irrespective of the remedies provided by the domestic law of those States‚ present a case to the competent authority of the Contracting State of which the person is a resident or‚ if the case comes under paragraph 1 of Article 23‚ to that of the Contracting State of which the person is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Agreement.
Source paragraph 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 this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States.
Source paragraph 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 this Agreement. They may also consult together for the avoidance of double taxation in cases not provided for in this Agreement.
Source paragraph 4
(4) If the taxation of income in a Contracting State is effected by way of a withholding tax at source‚ and if this taxation is limited by the provisions of this Agreement‚ the application of this tax reduction or exemption shall be governed by the national law of that State in conjunction with the procedures agreed upon for this purpose between the competent authorities of the two Contracting States.
Source paragraph 5
(5) The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.