- 1
- Where difficulties or doubts arise between the Contracting Parties regarding the implementation or interpretation of this Agreement, the competent authorities shall endeavour to resolve the matter by mutual agreement.
- 2
- In addition to the agreements referred to in paragraph 1, the competent authorities of the Contracting Parties may mutually agree on the procedures to be used under this Agreement.
- 3
- The competent authorities of the Contracting Parties may communicate with each other directly for purposes of reaching agreement under this Article.
- 4
- If any difficulty or doubt arising as to the interpretation or application of the Agreement cannot be resolved by the competent authorities of the Contracting 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 Contracting Party, be submitted for arbitration, but only after fully exhausting the procedure available under paragraphs 1 and 3 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 Contracting Parties and the taxpayers involved with respect to that case.
- 5
- The Contracting Parties may also agree on other forms of dispute resolution.
