Mutual Agreement Procedure
(1) If someone considers that the measure taken by one or both of the Contracting States will (or may) result in imposing taxes with prejudice to the provisions of this Convention, he/she may, regardless the settlement procedures stipulated in the national legislations of those States, object these measures before the competent authority of the Contracting State in which he/she is a resident, if his condition falls under the provisions of paragraph (1) of Article 25, of the State of which he is a resident. The objection shall be within three years from the first-notification of the procedure that has led to the imposition of tax contrary to the provisions herein.
(2) The competent authority shall, if the objection is justifiable and it was unable to settle the matter, endeavour to reach an agreement with the competent authority of the other Contracting State in order to avoid a taxation contrary to the provisions hereof. The reached agreement shall be implemented regardless any time deadlines included in the national legislations of both Contracting States.
(3) The competent authorities of both Contracting States shall endeavour to resolve, by mutual agreement, any disputes or doubts arising due to the application or interpretation hereof. They also may consult each other to avoid double taxation in cases not included herein.
(4) The competent authorities of the two Contracting States may communicate with each other directly through a joint committee composed of themselves or their representatives in order to reach an agreement in accordance with the meaning of the preceding paragraphs.