It is understood that, if the competent authorities of the Contracting States have, by mutual agreement, reached a solution within the context of the Convention for cases in which
- a)application of paragraph 2 of Article 3 with respect to the interpretation of a term not defined in the Convention; or
- b)differences in qualification (for example of an element of income or of a person)
would result in double taxation or double exemption, this solution, after publication thereof by both competent authorities, shall also be binding for the application of the provisions of the Convention in other similar cases.
