Double taxation agreements distribute tax duties among countries. However, they do not create new revenue requirements. Where there are competing assets, they allocate tax legislation to only one of the countries concerned in order to avoid double taxation. 2. This Convention does not in any way limit any exclusion, exemption, deduction, credit or other compensation granted now or later: (a) by the laws of one of the two contracting states; or b) by another agreement to which the States Parties are parties. 6. The competent authorities of the contracting states may, by mutual agreement, define other modalities for the application of tax reductions under this Convention. 6. For the purposes of paragraph 5 and this paragraph, the following rules and definitions apply: (a) the term “person concerned” refers to the participant in the appeasement of a case addressed to a competent authority for remuneration under this article and, if so, any other person whose tax debt may directly affect one of the Member States by a reciprocal agreement resulting from that consideration; (b) “acceptance date” of a case, the earliest date when the information necessary to examine the content of a mutual agreement was received by the two competent authorities; (c) Arbitration begins following a case: a bis) two years after the start of this case, unless the two competent authorities have given their prior approval on another date, and bb) the date closest to the date on which the agreement provided for at point d) was concluded by the two competent authorities; (d) the person (s) concerned (s) and his authorized representatives or agents must agree, before the start of the arbitration procedure, not to disclose the information he has received from a contracting state or the arbitration body during the arbitration procedure, with the exception of the decision of that chamber, to other persons; (e) If a person concerned does not accept the decision of an arbitration body, the decision constitutes a consensual resolution under this article and binds the two States parties in that case; and (f) For the purposes of the arbitration procedure under paragraph 5 and this paragraph, members of the arbitration body and their agents are considered “persons or authorities” who may be disclosed in accordance with Article 26 (exchange of information and assistance). 2. The competent authority endeavours to resolve the matter by mutual agreement with the competent authority of the other State party, by mutual agreement, where the objection appears to be well founded and is not in a position to find a satisfactory solution to resolve the matter in agreement with the competent authority of the other contracting State, in order to avoid tax evasion which is not in accordance with this convention.
Any agreement reached will be implemented in the domestic law of the States Parties, regardless of any restrictions or other procedural restrictions.