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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Mutual Agreement Procedure

(1) If someone considers that the measure taken by one or both of the Contracting States will (or may) result in imposing taxes with prejudice to the provisions of this Convention, he/she may, regardless the settlement procedures stipulated in the national legislations of those States, object these measures before the competent authority of the Contracting State in which he/she is a resident, the objection shall be within three years from the first-notification of the procedure that has led to the imposition of tax contrary to the provisions herein.

(2) The competent authority shall, if the objection is justifiable and it was unable to settle the matter, endeavour to reach an agreement with the competent authority of the other Contracting State in order to avoid a taxation contrary to the provisions hereof. The reached agreement shall be implemented regardless of any deadlines included in the national legislations of both Contracting States.

(3) The competent authorities of both Contracting States shall endeavour to resolve, by mutual agreement, any disputes or doubts arising due to the application or interpretation hereof. They also may consult each other to avoid double taxation in cases not included herein.

(4) The competent authorities of both Contracting States may communicate with each other directly for the purpose of reaching an agreement on the meaning of the preceding paragraphs.