Australian Tax Treaties

Italian Convention  

CHAPTER V - SPECIAL PROVISIONS  

ARTICLE 25   Mutual Agreement Procedure  

(1)    
Where a resident of one of the Contracting States considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with this Convention, he may, notwithstanding the remedies provided by the national laws of those States, present his case to the competent authority of the Contracting State of which he is a resident. This case must be presented within two years from the first notification of the action.

(2)    
The competent authority shall endeavour, if the taxpayer ' s claim appears to it to be justified and if it is not itself able to arrive at an appropriate solution, to resolve the case with the competent authority of the other Contracting State, with a view to the avoidance of taxation not in accordance with this Convention.

(3)    
The competent authorities of the Contracting States shall endeavour to resolve any difficulties or doubts arising as to the application of this Convention.

(4)    
The competent authorities of the Contracting States may communicate with each other directly for the purpose of giving effect to the provisions of this Convention.