Mutual agreement procedure permits residents to seek competent authority resolution of treaty taxation conflicts within a specified filing period.

Article 25 provides that a resident may present a case to their competent authority when taxation by one or both Contracting States results or will result in taxation inconsistent with the Agreement; the competent authority shall, if the claim appears justified and it cannot itself resolve the matter, endeavour to settle the case with the other State's competent authority to avoid treaty-inconsistent taxation, implement any agreed solution notwithstanding domestic time limits, jointly resolve application difficulties, and communicate directly to effect the Agreement.

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