Mutual agreement procedure enables taxpayers to seek competent authority negotiations to resolve treaty-related taxation discrepancies and avoid improper double taxation.

The Mutual Agreement Procedure permits a person alleging taxation inconsistent with the DTAA to present the case to the competent authority of their residence or nationality within two years of the first notification. If the competent authority finds the objection justified but cannot itself resolve it, it shall seek a mutual agreement with the other Contracting State's competent authority to avoid taxation contrary to the Agreement; agreements presented within the time limit are to be implemented notwithstanding domestic time-limits. Competent authorities shall endeavour to resolve interpretive or application difficulties and may communicate directly or convene a Commission for oral exchanges.

---

---

---