Mandatory Binding Arbitration applies after Convention entry or upon mutual notification specifying case presentation dates.

Part VI (Arbitration) applies between two Contracting Jurisdictions to a Covered Tax Agreement for cases presented on or after the later of the dates the Convention enters into force for each jurisdiction; for cases presented earlier it applies when both jurisdictions notify the Depositary of a mutual agreement under Article 19(10) specifying the presentation date(s). Reservations permitting Part VI to apply to earlier cases require both competent authorities' agreement. Withdrawals, replacements, objections' withdrawals, extensions, and additional notifications take effect from the Depositary's communication date specified for each type of notification.

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