제19695호                               관              보                 2020. 2. 24.(월요일)
1.     Where a person considers that the actions of one or both of the Contracting States result
or will result for that person in taxation not in accordance with the provisions of this Convention,
that person may, irrespective of the remedies provided by the domestic law of those Contracting
States, present that person’s case to the competent authority of either Contracting State. 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.
                                             Article 24
                                  EXCHANGE OF INFORMATION
1.     The competent authorities of the Contracting States shall exchange such information as is
foreseeably relevant for carrying out the provisions of this Convention or to the administration or
enforcement of the domestic laws concerning taxes of every kind and description imposed on
behalf of the Contracting States, or of their political subdivisions or local authorities, insofar as
the taxation thereunder is not contrary to the Convention. The exchange of information is not
restricted by Articles 1 and 2.
2.     Any information received under paragraph 1 by a Contracting State shall be treated as
secret in the same manner as information obtained under the domestic laws of that State and
shall be disclosed only to persons or authorities (including courts and administrative bodies)
concerned with the assessment or collection of, the enforcement or prosecution in respect of, the
determination of appeals in relation to the taxes referred to in paragraph 1, or the oversight of
the above. Such persons or authorities shall use the information only for such purposes. They
may disclose the information in public court proceedings or in judicial decisions.
3.     In no case shall the provisions of paragraphs 1 and 2 be construed so as to impose on a
Contracting State the obligation:
       a)      to carry out administrative measures at variance with the laws and administrative
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