Mutual agreement procedure allows taxpayers to ask competent authorities to resolve treaty-related taxation conflicts through negotiation.

A taxpayer who considers that taxation by one or both Contracting States is not in accordance with the Agreement may present the case to the competent authority of residence or nationality within the treaty's time limit. The competent authority, if it deems the objection justified and cannot itself resolve it, shall seek a mutual agreement with the other State to avoid treaty-inconsistent taxation; such agreements must be implemented notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretive or application doubts, may consult to eliminate double taxation not covered by the Agreement, communicate directly, and, if advisable, conduct oral exchanges through a Commission of their representatives.

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