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