ARTICLE 24
Mutual Agreement Procedure
(1) Where a person considers that the actions of one or both of the Contracting States result in or will result for him in taxation that is not in accordance with the provisions of this Convention, he may, notwithstanding the remedies provided by the domestic laws of these States, submit his case to a competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph (1) of Article 23, to that of the Contracting State of which he is a national. The case must be presented within three years from the first-notification of the action resulting in taxation not in accordance with the provisions of the Convention.
(2) The competent authority shall endeavour, if the objection appears to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation that may not be in accordance with the Convention. Any agreement reached shall be implemented notwithstanding any time limits in the domestic laws of the Contracting States.
(3) 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 the Convention. They may also consult together for the elimination of double taxation in cases not provided for in the Convention.
(4) The competent authorities of the Contracting States or their representatives may communicate directly with each other order to reach an agreement, as indicated in the preceding paragraphs of this Article, if necessary, through a commission consisting of themselves or their representatives.