Mutual Agreement Procedure
(1) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic laws 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 24, to that of the Contracting State of which he is a national. The case must be presented within two years from the issuance of the assessment not in accordance with the provisions of this Agreement.
(2) The competent authority shall endeavour, if the objection appears to it 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 is not in accordance with the Agreement.
Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States, concerning their internal statute of limitation.
(3) The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in the Agreement.
(4) The provisions of this Agreement regarding the reduction or exemption from taxes on income in the Contracting States where it arises shall be applied in accordance with the laws of that State and the procedures to be agreed by the competent authorities of both Contracting States.
(5) 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.