Determine the matched provisions
A covered agreement must be in force and notified by the relevant contracting parties. The instrument addresses hybrid mismatches, treaty abuse, permanent-establishment avoidance and dispute resolution, but optional articles and reservations mean its full text does not automatically amend every treaty. Read the bilateral agreement together with both jurisdictions deposited positions and the compatibility clauses for the specific article.
Separate dispute procedures and commencement
Mandatory arbitration applies only where both parties opt in, subject to reservations, case information and court-decision conditions. The standard text uses a two-year unresolved MAP period but permits a three-year reservation; confidentiality, acceptance and implementation also matter. Entry into force of the convention is different from entry into effect for withholding taxes, other tax periods and arbitration. Check the relevant deposited instruments and dates before claiming a treaty benefit or procedural right.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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