ARTICLE 22
Mutual Agreement Procedure
(1) Where a person resident in a Contracting State considers that the actions of a Contracting State or both Contracting States have resulted or will result for him in taxation not in accordance with the provisions of this Convention, the competent authorities shall endeavour to resolve the case by mutual agreement with a view to the avoidance of taxation not in accordance with this Convention.
(2) 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 this Convention. They may also consult together following the prescribed procedure for the elimination of double taxation in cases not provided for in this Convention.
(3) The competent authorities of the Contracting States may communicate with each other directly for the purpose of the application of this Convention.