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CHAPTER I - GENERAL PROVISIONS
CHAPTER II - TAXATION OF INCOME AND CAPITAL
CHAPTER III - TAXATION OF ESTATES, INHERITANCE AND GIFTS
CHAPTER IV - ASSISTANCE IN TAX MATTERS
CHAPTER V - PROTECTION OF THE TAXPAYER AND MUTUAL AGREEMENT
CHAPTER VI - SPECIAL PROVISIONS
CHAPTER VII - FINAL PROVISIONS
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.

ARTICLE 34

Appeal

(1) An appeal against measures taken by the requested State under Article 32 shall be lodged only with the competent authorities of that State under domestic law.

(2) An appeal against measures taken by the requesting State relating to the existence or the level of a tax claim or an enforcement order shall be lodged only by the competent authorities of that State under domestic law. The requesting State shall notify the requested State without delay that an appeal has been lodged. Upon receipt of the notification, the requested State shall suspend proceedings for collection until the decision of the competent authority is available. The requested State may, however, if asked to do so by the requesting State, adopt precautionary measures to ensure collection. Any Party may also notify the requested State when an appeal has been lodged. Upon receipt of the notification, the requested State shall if necessary consult the requesting State.

(3) As soon as a final decision on the appeal has been taken, the requesting or the requested State shall notify the other State of the decision and its effects on the request for collection. The two States shall, if necessary, discuss whether the request for collection should be maintained.