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1. Where difficulties or doubts arise between the Contracting States regarding the implementation or interpretation of the Agreement, the competent authorities shall endeavour to resolve the matter by mutual agreement.
2. In addition to the agreements referred to in paragraph 1, the competent authorities of the Contracting States may mutually agree on the procedures to be used under Articles 5 and 6.
3. The competent authorities of the Contracting States may communicate with each other directly for purposes of reaching agreement under this Article.
4. If any difficulty or doubt arising as to the interpretation or application of the Agreement cannot be resolved by the competent authorities of the Contracting States in a mutual agreement procedure pursuant to the previous paragraphs of this article within a period of two years after the question was raised, the case may, at the request of either Contracting State, be submitted for arbitration, but only after fully exhausting the procedure available under paragraphs 1 and 3 of this Article and provided the taxpayer or taxpayers involved agree in writing to be bound by the decision of the arbitration board.
The decision of the arbitration board in a particular case shall be binding on both Contracting States and the taxpayers involved with respect to that case.