A request for arbitration may only be made after two years from the date on which a case presented to the competent authority of one Contracting State under paragraph 1 of Article 25 has also been presented to the competent authority of the other State. For this purpose, a case shall be considered to have been presented to the competent authority of the other State only if the following information has been adequately presented:
- a)the full names and addresses of the parties to which the mutual agreement procedure relates, together with the tax office and tax reference details (such as tax identification number);
- b)the tax period(s) concerned;
- c)the nature and date of the action(s) giving rise to the taxation not in accordance with the Convention; and
- d)any specific additional information requested by the competent authority within two months upon receipt of the tax payer’s request.
