5. Enterprises of a Contracting State the capital of which is whote or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State may not be subject in the first-mentioned State to any taxation or requirement which is different or heavier than the taxation and related requirements to which other similar enterprises of the first state. 6. In Ireland, subject to the provisions of Irish law relating to the deduction as an entry in the accounts of Irish tax due in a territory outside Ireland (which does not affect the general principle of this scheme), double taxation shall be abolished as follows: 3. The competent authorities of the Contracting States shall endeavour to identify any difficulty or doubt arising from the interpretation or application of the Convention; by mutual agreement. They may also consult each other on the elimination of double taxation in cases not provided for in the Convention. 2. Where a competent authority has suspended the mutual agreement procedure referred to in paragraph 1 by reason of proceedings before a court or administrative tribunal concerning one or more of the same matters, the period referred to in point (b) of paragraph 1 shall no longer apply until a final decision of the administrative court or tribunal has been taken, or that the case has been suspended or withdrawn. If a person who has submitted a case and a competent authority have agreed to suspend the mutual agreement procedure, the period provided for in paragraph 1 (b) shall no longer run until the suspension has been lifted. 3.
Paragraphs 1 and 2 below shall not apply to income received by a State established in a Contracting State from activities carried on in the other State Party, where the visit to that other State is wholly or mainly borne by public funds of one or both States Parties or of political subdivisions or territorial collectivities; or within the framework of a cultural agreement or a cultural agreement between the governments of the States Parties. In this case, the income is taxable only in the Contracting State in which the artist or athlete resides. With the intention of concluding a new convention to eliminate double taxation on income and capital gains, without creating opportunities for non-taxation or tax reduction through tax evasion or avoidance (including through agreements to purchase contracts to obtain relief under this Convention for indirect persons from third countries), Countries with which the Netherlands is currently negotiating double taxation conventions: 1. If a person considers that the conduct of one or both Contracting States will result in or will result in taxation of that person which is not in conformity with the provisions of this Convention, he may refer the matter to the competent authority of a Contracting State, irrespective of the remedies provided for by the national law of those States. The case must be submitted within three years of the first notification of the appeal leading to non-taxation in accordance with the provisions of the Agreement. (a) The competent authority which received the initial request for a mutual agreement procedure referred to in Article 24(1) shall, within sixty days of receipt of the request: CONSIDERING that it was made by Section 826 (1) (in the Tax Consolidation Act 1997 1997 (No 1) of Section 157 of the Finance Act 2010 (No 5 of 2010).