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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 Agreement.

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 this Agreement. 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 Agreement.

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.

ARTICLE 25

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 Agreement 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 Agreement. The exchange of information is not restricted by Articles1 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 2 be construed so as to impose on a Contracting

State the obligation:

(a) to carry out administrative measures at variance with the laws and administrative practice of that or of

the other Contracting State;

(b) to supply information which is not obtainable under the laws or in the normal course of the

administration of that or of the other Contracting State;

(c) to supply information which would disclose any trade, business, industrial, commercial or professional

secret or trade process, or information the disclosure of which would be contrary to public policy (ordre public).

4. If information is requested by a Contracting State in accordance with this Article, the other Contracting

State shall use its information gathering measures to obtain the requested information, even though that other

State may not need such information for its own tax purposes. The obligation contained in the preceding

sentence is subject to the limitations of paragraph 3 but in no case shall such limitations be construed to

permit a Contracting State to decline to supply information solely because it has no domestic interest in such

information.

5. In no case shall the provisions of paragraph 3 be construed to permit a Contracting State to decline to

supply information solely because the information is held by a bank, other financial institution, nominee or

person acting in an agency or a fiduciary capacity or because it relates to ownership interest in a person.

ARTICLE 26

Members of diplomatic missions and consular posts

Nothing in this Agreement shall affect the fiscal privileges of members of diplomatic missions or consular

posts under the general rules of international law or under the provisions of special agreements.