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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 25

Mutual Agreement Procedure

(1) Where a person considers that the actions of one or both of the Contracting States result in or will result for him in taxation that is not in accordance with the provisions of this Convention, he may, notwithstanding the remedies provided under the domestic laws of the Contracting States, submit his case to the competent authority of the Contracting State of which he is a resident or, if his case falls under paragraph (1) of Article 24, to the competent authority of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of this Convention.

(2) The competent authority shall endeavour, if the objection appears 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 avoid taxation that 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 any difficulty or doubt arising from the interpretation or application of this Convention. They may also consult each other regarding the elimination of double taxation in cases not provided for in this Convention.

(4) After the expiry of the specified period under the domestic laws of a Contracting State, and in any case, after the expiry of five years from the end of the taxable period in which the taxable income is derived, the tax base of a resident of a Contracting State shall not be increased in either of the Contracting States by adding items of income which may have been taxed in the other Contracting State.