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