Page 456 - ΔΟΚΙΜΗ

ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ 1984 447
olaim 1s made, it shall endeavor to oome to an agreement
with the oompetent authority ot the other Contraoting State
with a view to the avoidance of taxation contrary to the
provisions of this Convention.
(2) The competent authorities οΙ the Contraoting 5tates
shall endeavor to resolve by mutual agreement any
4iffiou1ties or doubts arising βθ to the application ο! this
Convention. Ιη partioular, the competent authoritiee ο! the
Contracting States may agree:
(a) Το the same attribution ο! income, deductions,
oredits or al10wances ο! a resident of a
Contraoting State to its permanent establiehment
situated ίη the other Contraoting State;
(b) Το the same allocation ο! income, deductions,
credits, οτ al10wances between persone, lncluding a
unlform poeition οη the applioation ο! the requirements
of paragraph (2) ο! Artiole 7 (Non-Discrimination);
(ο) Το the same determination ο! the souroe of
particular items ο! lncome;
(d) Το a un1form accounting for income and deductions;
(e) Το the same oharacterization of particular items
ο! income; and
(f) Το a COIΏIIloη meaning of a term.
The competent autllori ties may 81so consul t together for the
e1imination ο! doub1e taxation in cases not provided for ίη
the Convention.
(3) The competent autl10ri ties οΙ the Contracting States
may communicate with each other directly for the purpose
of reaohing an agreement ίη the sense ο! this Article.
When it seams advisable for the purpose ο! reaching
agreement, the competent authorities may meet together
for an οτβl exchange ο! opinione.
(4) Ιη the event that the competent authorities ο! the
Contraoting States reach such an agreement, taxes shal1 be
imposed and refund οτ oredit ο! taxee shall be allowed by
the Contracting States in aocordance with euch agreement.
Such a refund οτ credit ο! tax ehall be al10wed notwith–
standing any time limits in the domestic law of the
Contracting States.