Mutual Agreement Procedure enables taxpayers to seek cross border relief through competent authorities who must seek agreement to avoid inconsistent taxation.

The Mutual Agreement Procedure allows a person alleging taxation contrary to the Convention to present the case to the competent authority of residence or nationality within a specified period. If the competent authority finds the objection justified but cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to prevent taxation inconsistent with the Convention, and any agreement reached shall be implemented notwithstanding domestic time-limits. Authorities may directly consult, resolve interpretive doubts, and use a Commission for oral exchanges to eliminate double taxation.

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