第1條
Where a person considers that the actions of one or both of the Contracting Parties result or will result for that person in taxation not in accordance with the provisions of this Agreement, that person may, irrespective of the remedies provided by the domestic laws of those Parties, present a case to the competent authority of the Contracting Party of which that person is a resident or, if that case comes under paragraph 1 of Article 22, to that of the Contracting Party in which that person has the right of abode or is incorporated or otherwise constituted (in the case of the Hong Kong Special Administrative Region) or of which that person is a national (in the case of New Zealand). 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 Agreement.