The competent authorities of Switzerland and the U.S. have entered into the following Competent Authority Arrangement regarding the implementation of the arbitration process provided for in paragraphs 6 and 7 of Article 25 of the Convention between the Swiss Federation and the United States of America for the Avoidance of Double Taxation with Respect to Taxes on Income, signed at Washington on October 2, 1996, as Amended by the Protocols signed on October 2, 1996, and September 23, 2009 (the “Convention”) and the exchange of notes accompanying the 2009 Protocol which form an integral part of the Convention.