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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.


Application of the Agreement in Specific Cases

(1) This agreement may not be interpreted as if it hindered either Contracting State in the application of provisions of domestic law on the prevention of fiscal fraud or fiscal evasion.

(2) If the provisions above lead to double taxation, the responsible authorities will consult with each other according to paragraph (3) of Article 24, in order to prevent double taxation.