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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 shows proof that the action of. the tax authorities of the Contracting States has resulted or will result in double taxation contrary to the provisions of this Agreement he shall be entitled to present his case to the State of which he is resident. Should his claim be deemed worthy of consideration, the competent authority of the State to which the claim is made shall endeavour to come to an agreement with the competent authority of the other State with a view to avoidance of double taxation.

(2) For the settlement of difficulties or doubts in the interpretation or application of this Agreement or in respect of its relations to Agreements of the Contracting States with third States the competent authorities of the Contracting States shall reach a mutual agreement as quickly as possible.