The other contracting state can only tax the profits of the property to the extent that those profits have not been realized, whereas the person was established in the first state. However, this provision does not apply to property for which the other State party could have, under paragraphs 1 to 4 of this article, taxed the profit if the person had made the profit before residing in that other Contracting State. The competent authorities endeavour to resolve by mutual agreement any issues that may arise from the application of this paragraph and the national legislation of the contracting states when a person no longer has his domicile in a contracting state and is treated by that State for the taxation, for the purposes of taxation in that State, of the disposal of a property and a corresponding taxation in that state. (b) royalties for the use or right to use software or computer patents, or for information on commercial, commercial or scientific experience (excluding royalties granted in connection with a lease or franchise agreement); 4 The competent authorities of the contracting states endeavour to resolve by mutual agreement any difficulty or doubt about the interpretation or application of this convention. They can also agree on the elimination of double taxation in cases not provided for by this convention. The BEPS 14 (Making Dispute Resolution Mechanisms More Effective) report requires legal systems to set a minimum standard to ensure that they resolve treaty disputes in a timely, efficient and effective manner. All members of the Integrated Framework for BEPS (IF) are committed to implementing the minimum standards of Action 14, which include a rapid and comprehensive report on the statistics of the Mutual Agreement Procedure (MAP), in accordance with an agreed report framework. Pop 2019 statistics will be published as part of this new framework. They cover all members who joined the IF before 2020. 3 For the purposes of Article XXII, paragraph 3 (consultation), of the General Agreement on Trade in Services of the World Trade Organization Agreement, concluded in Marrakech on 15 April 1994, States Parties agree that, notwithstanding this paragraph, any dispute between them over whether a measure falls within the scope of that agreement can be submitted to the Council for Trade in Services. , as provided in this paragraph, only with the agreement of the two States Parties. Any question relating to the interpretation of this paragraph is lifted in accordance with paragraph 4 of Article 23 (procedure of mutual agreement) or, if an agreement is not reached under that procedure, according to another procedure agreed by the two States Parties.
2 The competent authority referred to in paragraph 1 endeavours to resolve the matter by mutual agreement with the competent authority of the other State party, by mutual agreement with the competent authority of the other State party, in order to avoid tax evasion that is not in accordance with this convention.