Mutual Agreement Procedure
(1) Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in double taxation not in accordance with the Convention, he may, without prejudice to the remedies provided by the national laws of those States, make written application for a review of the said taxation to the competent authority of the Contracting State of which he is a resident. Even where the taxation found to be not in accordance with the Convention can no longer be annulled or reduced under the laws of the Contracting State in which it was imposed, such application may still be submitted within two years from the date of notification or of deduction at the source of the second taxation. If the person concerned has, under the laws of a Contracting State, contested the taxation imposed on him in that State, the aforementioned time limit shall not expire until one year after the date on which the taxation has become final.
(2) The competent authority referred to in paragraph (1) shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of double taxation not in accordance with the Convention.
(3) The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the application of the Convention.
(4) The competent authorities of the Contracting States shall agree on the administrative measures required for the implementation of the provisions of the Convention, and in particular on the evidence to be produced by residents of each State in order to enjoy in the other State the tax exemptions or reductions provided for in this Convention.