- 1
- The competent authorities of the Contracting Parties shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. Consultation requested by the competent authority of a Contracting Party shall begin within 90 days from the date of the receipt of such request.
- 2
- The competent authorities of the Contracting Parties may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraph.
- 3
- If any difficulty or doubt arising as to the interpretation or application of the Agreement cannot be resolved by the competent authorities of the Parties in a mutual agreement procedure pursuant to the previous paragraphs of this Article within a period of two years after the question was raised, the case may, at the request of either Party, be submitted for arbitration, but only after fully exhausting the procedures available under paragraphs 1 to 2 of this Article and provided the taxpayer or taxpayers involved agree in writing to be bound by the decision of the arbitration board.
- The decision of the arbitration board in a particular case shall be binding on both Parties and the taxpayer or taxpayers involved with respect to that case.
