1. Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Convention, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or national.
2. If the objection appears to be justified to such competent authority, and if it is not itself able to arrive at a satisfactory solution, then it shall present the case to the competent authority of the other Contcacting State, and the competent authorities shall endeavor to resolve the case by mutual agreement, with a view to the avoidance of taxation which is not in accordance with the Convention. Any agreement reached shall be implemented notwithstanding any time limits or other procedural limitations in the domestic law of the Contracting States.
3. The competent authorities of the Contracting States shall endeavor to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Convention. In particular the competent authorities of the Contracting States may agree:
a) to the same attribution of income, deductions, credits, or allowances of an enterprise of a Contracting State to its permanent establishment situated in the other Contracting State;
b) to the same allocation of income, deductions, credits, or allowances between persons;
c) to the same characterization of particular items of income;
d) to the same application of source rules with respect to particular items of income;
e) to a common meaning of a term;
f) to increases in any specific amounts referred to in the Convention to reflect economic or monetary developments; and
g) to the application of the provisions of domestic law regarding penalties, fines, and interest in a manner consistent with the purposes of the Convention.
They may also consult together for the elimination of double taxation in cases not provided for in the Convention.
4. The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of the preceding paragraphs.
5. The competent authorities of each of the Contracting States may prescribe regulations to carry out the purposes of this Convention.
