by an enterprise of a Contracting State to a resident of the other Contracting State shall,

for the purpose of determining the taxable profits of such enterprise, be deductible under

the same conditions as if they had been paid to a resident of the first-mentioned State.

Similarly, any debts of an enterprise of a Contracting State to a resident of the other

Contracting State shall, for the purpose of determining the taxable capital of such enter-

prise, be deductible under the same conditions as if they had been contracted to a resi-

dent of the first-mentioned State.

5. 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 State to any taxation or any require-

ment 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.

6. The provisions of this Article shall, notwithstanding the provisions of Article 2,

apply to taxes of every kind and description.

ARTICLE 25

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

those 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 24, to that of

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

years from 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 jus-

tified 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 domes-

tic 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 appli-

cation of the Convention.

4. The competent authorities of the Contracting States may communicate with each

other directly, including through a joint commission consisting of themselves or their

representatives, for the purpose of reaching an agreement in the sense of the preceding

paragraphs.

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