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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.


Interpretation of the Convention

(1) Where a person considers that the measures taken by a Contracting State or by the Contracting States result in or will result for him in taxation not in accordance with the provisions of this Convention, he or she may, notwithstanding the remedies provided under the domestic laws of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph (1) of Article 23 of this Convention, to that Contracting State of which he is a national. The case must be presented within two years after the first-notification of the action resulting in taxation not in accordance with the provisions of the Convention.

(2) Each Contracting State is entitled to make a request regarding the interpretation of the provisions of this Convention when it becomes clear to it that the other Contracting State has implemented or is in the process of implementing one of these provisions inappropriately or not in accordance with the aims and objectives for the prevention of double taxation.

(3) The request for interpretation should be submitted to the other Contracting State through regular diplomatic channels specifying the place and date of the meeting of the Committee as laid down in paragraph (3) of this Article.

The interpretation shall be carried out by a committee of two representatives, or more, of each Contracting State, one of whom should be a specialist in financial and tax systems of his country.

(4) The interpretation resulting from a mutual agreement shall form an integral part of this Convention.