Arbitration bindingness: arbitration may be non-binding if competent authorities agree a different resolution after delivery.

An arbitration decision under the Convention is not binding and will not be implemented if the competent authorities of the two Contracting Jurisdictions agree on a different resolution of all unresolved issues within three calendar months after the arbitration decision is delivered, provided both Contracting Jurisdictions have notified the Depositary that they adopt this option; a Party may reserve that this option apply only to Covered Tax Agreements subject to the specified arbitration process.

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