Mutual agreement procedure allows taxpayers to ask competent authorities to resolve treaty-related taxation not in accordance with the agreement.

The Article provides a mutual agreement procedure permitting a resident to present a case to the competent authority within three years of the first notice if actions of one or both Contracting States cause taxation inconsistent with the Agreement; the competent authority must seek resolution by mutual agreement with the other State's competent authority and implement any agreement notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation beyond the Agreement's text, communicate directly, and may use a Commission for oral exchanges to reach agreement.

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