Mutual Agreement Procedure enables taxpayers to seek competent authorities' direct mutual resolution of taxation conflicts through consultation.

Article 25 provides that a person alleging taxation inconsistent with the Agreement may present the case to the competent authority of residence or nationality within the prescribed presentation time limit; the competent authority shall, if the objection appears justified and it cannot itself resolve the issue, seek a mutual agreement with the other State's competent authority to avoid inconsistent taxation, implement any agreement notwithstanding domestic time limits, consult on interpretation or application issues, communicate directly, and, if necessary, hold oral exchanges through a Commission of representatives.

---

---

---