Mutual Agreement Procedure enables taxpayers to seek competent authority resolution to avoid taxation inconsistent with a tax treaty.

The Mutual Agreement Procedure allows a person who regards actions by one or both Contracting States as resulting in taxation contrary to the Agreement to present the case to the competent authority of the State of residence or nationality within three years of notification. The competent authority shall, if it deems the objection justified and cannot itself resolve it, seek a mutual agreement with the other Contracting State to avoid taxation inconsistent with the Agreement, implement any agreement notwithstanding domestic time-limits, consult on interpretation or application difficulties, and may communicate directly or via a Commission of representatives.

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