Mutual agreement procedure enables competent authorities to resolve treaty-based taxation disputes and eliminate inconsistent taxation.

A taxpayer who considers that actions of one or both Contracting States result in taxation not in accordance with the Convention may present a case to the competent authority of the State of residence or nationality within three years of first notification. If the competent authority finds the objection justified and cannot itself obtain a satisfactory solution, it shall endeavour to resolve the case by mutual agreement with the competent authority of the other Contracting State, and any agreement reached shall be implemented irrespective of domestic time limits.

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