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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.

ARTICLE 27

Mutual Agreement Procedures

(1) Where a person considers that the measures of one or both of the Contracting States result or may result for him in taxation that is not in accordance with the provisions hereof, he may, irrespective of the challenges provided by the domestic law of those States, object to such measures and present his case to the competent authority of the Contracting State of which he is a resident, or, if his case is subject to Paragraph (1) of Article (24) of this Convention, present his case to the competent authority of the Contracting State of which he is a national, provided that the case must be presented within three years as of the first-notification of the measure resulting in taxation not in accordance with the provisions of the Convention.

(2) If the competent authority finds that, the objection is justified and is not itself able to reach a satisfactory solution, such authority shall spare no effort 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 levied not in accordance with the Convention. Any Agreement so reached shall be enforced notwithstanding any time limits set forth in the domestic law of the Contracting States.

(3) The competent authorities of the Contracting States shall endeavour to resolve by mutual Agreement any disputes or doubts arising as to the interpretation or application of the Convention. They may also consult each other, 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 even by forming a joint committee of the mentioned authorities or their representatives for the purpose of reaching an Agreement in the sense of Paragraphs (2) and (3) of this Convention.