МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 25
                      Mutual agreement procedure

     1.  Where  a  person considers that the actions of one or both of
the Contracting State result or will result for him in taxation not in
accordance   with   the   provisions   of  this  Convention,  he  may,
irrespective  of  the  remedies  provided by the domestic law of those
States, present his case to the competent authority of the Contracting
State  of which he is a resident or, if his case comes under paragraph
1  of  Article  24,  to that of the Contracting State of which he is a
national. The case must be presented within three years from the first
notification  of  the  action  resulting in taxation not in accordance
with the provisions of the Convention.
     2.  The  competent  authority  shall  endeavour, if the objection
appears  to  it to be justified and if it is not itself able to arrive
at  a  satisfactory  solution, to resolve the case by mutual agreement
with  the  competent  authority of the other Contracting State, with a
view  to the avoidance of taxation which is not in accordance with the
Convention. Any agreement reached shall be implemented notwithstanding
any  time  limits  provided for in the domestic law of the Contracting
States.
     3.  The  competent  authorities  of  the Contracting States shall
endeavour  to  resolve  by mutual agreement any difficulties or doubts
arising  as  to  the  interpretation or application of the Convention.
They  may also consult together for the elimination of double taxation
in cases not provided in the Convention.
     4.  The  competent  authorities  of  the  Contracting  States may
communicate  with  each  other directly for the purpose of reaching an
agreement in the sense of the preceding paragraphs.