Mutual Agreement Procedure enables resolution of treaty-inconsistent taxation via competent authority agreements enforceable despite domestic time limits.

The Mutual Agreement Procedure allows a person alleging taxation contrary to the Agreement to present the case to the competent authority of residence or nationality; the competent authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Agreement, implement any agreement notwithstanding domestic time limits, resolve interpretation or application difficulties, consult to eliminate double taxation, communicate directly, and, if needed, convene a Commission for oral exchanges.

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