Article 25 Mutual Agreement

1) Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this contract, he may, irrespective of the remedies provided by the domestic law of those States, present his case competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 24, the Contracting State of which he is 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 the Treaty.

2) If the competent authority of the objection to be justified and if it is not itself able to arrive at a satisfactory solution, they will try to resolve the case by mutual agreement with the competent authority of the other Contracting State, to avoid taxation not in accordance with this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the national law of the Contracting States.

3) The competent authorities of the Contracting States shall endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application thereof. They may also consult together for the avoidance of double taxation in cases not provided for in the Treaty.

4) The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.