(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, 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
three years from the first notification of the action resulting in taxa-
tion not in accordance with the provisions of 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 imple-
mented 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 Con-
vention. They may also consult together for the avoidance 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.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.
de-romania-2003-base | BGBl. 2003 II S. 1594 | signed 2001-07-04 | published 2003-11-14 | Signed: 2001-07-04 | Gazette publication: 2003-11-14
Source form
Original official-publication PDF retained unchanged. Reader uses explicit native-font ToUnicode derivative; exact original word text and geometry unchanged, no OCR.
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
German and English are separate complete physical source regions. The closing also names Romanian, NOT printed as a separate language version in this retained original; no Romanian asset or translation. English precedence clause is retained. 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-romania-2003-base/. PDF page links identify pages, not verified paragraph correspondence. Native Type1 diagnostic recovery: all used font codes independently mapped and glyphs loaded; only overlong Copyright metadata lines remain as retained Poppler warnings. No text repair or warning suppression. Full machine evidence and full physical pages: /geometry/de-romania-2003-base/.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2001-07-04; consent law 2003-11-12; gazette publication 2003-11-14. Edition ID year is not a signature date. Treaty entry into force: 2003-12-17. Roster general application: 2004-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 17. Dezember 2003. 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.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Rumänien R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. 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.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2003 II S. 1594 | de-romania-2003-base | de-romania-2003-base | BGBl. 2003 II S. 1594 | signed 2001-07-04 | published 2003-11-14 | Signed: 2001-07-04 | Gazette publication: 2003-11-14 | Article 25 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-romania-2003-base/en/articles/article-25/
Source, edition and limits
Source edition
de-romania-2003-base | BGBl. 2003 II S. 1594 | signed 2001-07-04 | published 2003-11-14 | Signed: 2001-07-04 | Gazette publication: 2003-11-14
Source form
Original official-publication PDF retained unchanged. Reader uses explicit native-font ToUnicode derivative; exact original word text and geometry unchanged, no OCR.
Source scope
original implementing law, multilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
German and English are separate complete physical source regions. The closing also names Romanian, NOT printed as a separate language version in this retained original; no Romanian asset or translation. English precedence clause is retained. 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-romania-2003-base/. PDF page links identify pages, not verified paragraph correspondence. Native Type1 diagnostic recovery: all used font codes independently mapped and glyphs loaded; only overlong Copyright metadata lines remain as retained Poppler warnings. No text repair or warning suppression. Full machine evidence and full physical pages: /geometry/de-romania-2003-base/.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2001-07-04; consent law 2003-11-12; gazette publication 2003-11-14. Edition ID year is not a signature date. Treaty entry into force: 2003-12-17. Roster general application: 2004-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 17. Dezember 2003. 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.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Roster future-instrument/negotiation entry (NOT proof of operative amendment): Rumänien R-P V. P = Paraphierung (initialled), NOT signature; U = signed, ratification pending; V = negotiation. R-P protocol/R-A replacement. 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.
Text language and status
en · authentic-language-transcription · machine-transcription