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 23, 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. They may also consult together for the elimination of double taxation in  cases not provided for in 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.