2.365 The amicable solution between the competent authorities of the countries concerned must be transposed into the national legislation of the countries covered by the tax convention, regardless of any time limits. This gives the competent authorities the flexibility to find a satisfactory solution and avoids problems that could arise if each country has a different time limit in its domestic law. [Article 25, paragraph 2] 5.30 The existing tax treaty, although it has offered a good level of protection against double taxation and the prevention of fiscal evasion since its entry into force, is no longer sufficiently adapted to the positions desired by both partners, given the close economic ties between Australia and New Zealand and the desire of both countries to further improve this relationship. .