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1. Where an entity considers that the actions of one or both of the Contracting States result or will result for it in taxation not in accordance with the provisions of this Convention, it may, irrespective of the remedies provided by the domestic law of those States, present its case to either competent authority. 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, or, if later, within six years from the end of the year or the chargeable period in respect of which that taxation is imposed or proposed.
2. The competent authority to whom the case has been presented 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, except such limitations as apply for the purposes of giving effect to such an agreement.
3. The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any double charging of bank taxes in cases not provided for in the Convention as well as 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.
5. Where,
a) under paragraph 1 or 3, a case has been presented to the competent authority of a Contracting State on the basis that the actions of one or both of the Contracting States have either resulted for that entity in taxation not in accordance with the provisions of this Convention, or in double charging of bank taxes in cases not provided for in this Convention, and
b) the competent authorities are unable to reach an agreement to resolve that case pursuant to paragraph 2 or 3 within two years from the presentation of the case to the competent authority of the other Contracting State,
any unresolved issues arising from the case shall be submitted to arbitration if an entity directly affected by the case so requests. Unless an entity directly affected by the case does not accept the mutual agreement that implements the arbitration decision, that decision shall be binding on both Contracting States and shall be implemented notwithstanding any time limits in the domestic laws of these States. The competent authorities of the Contracting States shall by mutual agreement settle the mode of application of this paragraph.