(1) The competent authorities of the Contracting States shall endeavour to eliminate by mutual agreement any difficulties or doubts which arise in the interpretation or application of this Agreement in general or in particular cases. They may also consider together how double taxation may be avoided in cases not covered by this Treaty or how matters related to taxes within the meaning of this Agreement which result from different criteria of the Contracting States for the tax base or for other reasons may be settled through a special agreement. They may further discuss together in order to attenuate or eliminate other difficulties resulting from differences in their tax laws and to combat international tax evasion and avoidance.
(2) The competent authorities of the Contracting States may conclude agreements by means of consultation in order:
- (a) to clarify future doubts as to which taxes are covered by this Agreement under its Article 2, paragraph (3);
- (b) to determine how the limiting provisions of this Agreement, particularly those in Articles 10 to 12, shall be implemented;
(3) The competent authorities of the Contracting States may consult together with respect to general regulations, in order to ensure, on the basis of this Agreement, a taxpayer's claim to co-ordinated application of this Agreement in both States through common interpretation or special procedures.