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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 41

Hearings

(1) The competent authorities of the Contracting State may communicate with each other directly for the purpose of reaching an agreement within the meaning of Articles 39 and 40.

(2) Where an oral exchange of opinions appears advisable in order to reach agreement, such exchange may take place through a commission consisting of representatives of the competent authorities of the Contracting States.

(3) The competent authorities may jointly request an independent body to deliver an expert opinion on a matter which they have brought before that body.

(4) If the hearing relates to a particular case, the persons involved shall be heard; they shall have the right to file their own motions.

(5) The provisions of chapters I, II and IV of the European Agreement on the Peaceful Settlement of Disputes of 29 April 1957 shall apply to the settlement of disputes in international law. The Contracting Parties may, however, agree to convene a court of arbitration whose decision is binding on them in place of the procedure laid down in that Agreement. Such court of arbitration shall consist of professional judges of the Contracting States or of third States or of international organizations. Its procedure shall be governed by the internationally recognized principles for arbitration procedures. The participants shall be granted full process of law and the right to file their own motions. The decision shall be handed down on the basis of the treaties in force between the two Contracting States and general international law; a decision ex aequo et bono shall not be permitted. Once an agreement on the convening and composition of the court of arbitration and on its rules of procedure has been reached, each of the Contracting States shall be at liberty to proceed in accordance with the first sentence of this paragraph.