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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 24

Mutual Agreement Procedure

(1) Where a person considers that the actions taken by one or both of the Contracting States result or will result for him or her in taxation not in accordance with the provisions of this Convention, he or she may, irrespective of the remedies provided by the domestic law of those States, present, to the competent authority of the Contracting State of which he or she is a resident, a written and reasoned request for revision of such taxation. To be admissible, the request must be presented within two years from the first-notification of the action resulting in taxation not in accordance with the provisions of this Convention.

(2) The competent authority referred to in paragraph (1) of this Article shall endeavour, if the objection appears to it 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 which is not in accordance with this Convention. Any agreement reached shall be implemented notwithstanding any time limits set forth in the domestic laws of the Contracting States.

(3) The competent authorities of the Contracting States shall endeavour, by mutual agreement, to resolve any difficulties or eliminate any doubts arising as to the interpretation or application of this Convention.

(4) The competent authorities of the Contracting States may consult each other for the elimination of double taxation in cases not covered by the Convention and may communicate with each other directly for the application of the Convention. If it appears that negotiations are required to reach an agreement, the matter may be referred to a committee composed of representatives of the governments of the Contracting States as specified by the competent authorities.