4. Enterprises of a Contracting State, the capital of which is wholly or partly owned

or controlled, directly or indirectly, by one or more residents of the other Contracting

State, shall not be subjected in the first-mentioned ContractingState to any taxation or

any requirement connected therewith which is other or more burdensome than the

taxation and connected requirements to which other similar enterprises of the first-

mentioned State are or may be subjected.

5. The provisions of this Article shall apply only to taxes which are covered by this

Convention.

ARTICLE 26

MUTUAL AGREEMENT PROCEDURE

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

theContracting States, present his case to the competent authority of the Contracting

State of which he is a resident or, if his case comes under paragraph 1 of Article 25, to

that of the Contracting State of which he is a national. The case must be presented

within three yearsfrom the first notification of the action resulting in taxation not in

accordance with the provisions of the Convention.

2. The competent authority shall endeavour, if the objection appears to it to be

justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case

by mutual agreement with the competent authority of the other Contracting State, 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 in the

domestic law of the Contracting States.

3. The competent authorities of the Contracting States shall endeavour to resolve

by mutual agreement any difficulties or doubts arising as to the interpretation or

application of 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. When it seems advisable in order to reach agreement to have an oral

exchange of opinions, such exchange may take place through a Commission consisting

of representatives of the competent authorities of the Contracting States.

ARTICLE 27

EXCHANGE OF INFORMATION

1. The competent authorities of the Contracting States shall exchange such

information as is foreseeably relevant for carrying out the provisions of this Convention

or to the administration or enforcement of the domestic laws concerning taxes of every

kind and description imposed on behalf of the Contracting States, or of their political or

administrative subdivisions or local authorities, insofar as the taxation thereunder is not

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