Mutual agreement procedure enables taxpayers to request competent authority resolution of treaty taxation mismatches and binding bilateral agreements.

The mutual agreement procedure allows a person who considers taxation contrary to the Convention to present the case to the competent authority of his State of residence or nationality within the three year period; the competent authority shall, if the objection appears justified and it cannot itself reach a solution, seek a mutual agreement with the other Contracting State to avoid incompatible taxation, implement any agreement notwithstanding domestic procedural time limits, and develop bilateral procedures while permitting unilateral facilitation.

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