ARTICLE 25

Mutual Agreement Procedure

(1) Where a person considers that the actions of one or both of the Contracting States result in or will result for him in taxation that is not in accordance with the provisions of the present Convention, he may, notwithstanding the remedies provided within the domestic laws of these States, subject his case to a competent authority of the Contracting State of which he is a resident or, if his case comes under Article 24 paragraph (1), 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 or the taxation by withholding at the source resulting in taxation not in accordance with the provisions of the Convention.

(2) This competent authority shall endeavor, if the objection appears 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 shall not be in accordance with the Convention. The grant shall be applicable irrespective of the deadlines given by the domestic laws of the Contracting State.

(3) The competent authorities of the Contracting States shall endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. They may also consult each other for the purpose of avoidance of double taxation in cases not covered by 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.