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

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, 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.

ARTICLE 26

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

contrary to the Convention. The exchange of information is not restricted by Articles 1

and 2.

2. Any information received under paragraph 1 by a Contracting State shall be

treated as secret in the same manner as information obtained under the domestic laws of

that State and shall be disclosed only to persons or authorities (including courts and

administrative bodies) concerned with the assessment or collection of, the enforcement

or prosecution in respect of, the determination of appeals in relation to the taxes referred

to in paragraph 1, or the oversight of the above. Such persons or authorities shall use the

information only for such purposes. They may disclose the information in public court

proceedings or in judicial decisions.

3. In no case shall the provisions of paragraphs 1 and 2be construed so as to

impose on a Contracting State the obligation:

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