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Article VI

Article VI

 

Paragraph 2 of Article 9 (Adjustment of income) of the Convention shall be deleted and replaced by the following:

"2. Where, in accordance with the provisions of paragraph 1, income which has been included by a Contracting State in the income of a person is also included by the other Contracting State in the income of another person, then the first State, if it considers that the adjustment made by the other State is justified both in principle and as regards the amount, shall make an appropriate adjustment to the amount of tax charged to the first person on such income. In determining this adjustment, due regard shall be paid to the other provisions of this Convention, and the competent authorities of the Contracting States, shall consult each other as necessary."