[Mutual Agreement Procedure]
(1) Any tax payer who can prove that the measures taken by the fiscal authorities of the Contracting Governments have resulted for him or her in double taxation insofar as the taxes covered by this Convention are concerned, can send a request, either to the competent authorities of the State on whose territory he or she has a fiscal domicile, or to the competent authorities of the other State. If the request appears to be justified, the competent authorities of the two States shall arrive at an Agreement for the avoidance of double taxation in a just manner.
(2) The competent authorities of the Contracting Governments may also reach an Agreement for the elimination of double taxation in cases not provided for under this Convention as well as cases where the application of the present Convention would give rise to difficulties.
(3) In case it appears that oral communication would facilitate reaching such an Agreement, such communication can take place in a joint commission consisting of an equal number of representatives of the Contracting Governments States appointed by the Ministers of Finance. The chairmanship of the commission shall be alternately held by a member of each delegation.