ARTICLE 26
Mutual Agreement Procedure
(1) Where a resident of a Contracting State considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident.
(2) The competent authority shall endeavour, if the objection appears to be justified and if he is not able to bring a satisfactory solution, to settle the question by mutual agreement with the competent authority of the other Contracting State, in order to avoid taxation, which is not in accordance with the provisions of this Convention.
(3) The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement, to solve the difficulties or doubts to which place the interpretation or the application of this Convention arises. 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 may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.