Mutual Agreement Procedure
(1) Where a person considers that the measures adopted by one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, this person 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 or, if his case comes under paragraph (1) of Article 23, to that of the Contracting State of which he is a national. The case must be presented within three years subsequent to the first notification of the action resulting in taxation not in accordance with the provisions of this Convention.
(2) The 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 avoid taxation which is not in accordance with this Convention. The convention shall be applicable irrespective of the terms provided by the domestic Law of the Contracting States.
(3) The competent authorities of the Contracting States shall endeavor to resolve any difficulties or doubts arising as to the interpretation or application of the Convention by way of mutual agreement. Likewise, they may mutually agree to avoid double taxation for cases not foreseen in the Convention.
(4) The competent authorities of the Contracting States may communicate with each other directly, or even through a joint committee comprised by the same or by their representatives, for the purpose of reaching a convention in the sense of the preceding paragraphs.