(1) This Agreement shall not be interpreted to mean that:
a) a Contracting State is prevented from applying its domestic legal provisions
on the prevention of tax evasion or tax avoidance;
b) the Federal Republic of Germany is prevented from levying taxes on amounts
which are to be included in the items of income of a resident of the Federal
Republic of Germany under the Fourth Part of the German Law on External
Tax Relations (Aussensteuergesetz).
(2) If the above provisions result in double taxation, the competent authorities shall
consult each other pursuant to paragraph 3 of Article 24 in order to eliminate double
taxation.