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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) 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 taxation not in accordance with 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.

(2) If the said competent authority considers the objection justified and is not itself able to arrive at a satisfactory solution, it shall 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 this Convention.

(3) The competent authorities of the Contracting States shall resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of this Convention. They may also consult together for the avoidance of double taxation in cases not provided for in the Convention. They shall also develop, by mutual agreement, the method of implementation of the limit provisions of this Convention regarding taxation at source.

(4) The competent authorities of the Contracting States may communicate with each other directly for the purpose of implementing this Convention.