Arbitration costs allocation under tax treaty: jurisdictions bear their own appointees' costs; chair and conduct expenses shared equally.

Arbitration costs, including panel members' fees and jurisdictional expenses, are to be borne by the Contracting Jurisdictions per mutual agreement of competent authorities; absent agreement, each jurisdiction bears its own expenses and those of its appointed panel member. Costs of the arbitration panel chair and other expenses related to conducting the arbitration are borne equally by the Contracting Jurisdictions.

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