Mutual agreement procedure: residents may request competent authorities to resolve treaty taxation conflicts through bilateral agreement.

A resident claiming taxation inconsistent with the DTAA may present the case to the competent authority of the State of residence within the treaty's prescribed period. The competent authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other State to avoid taxation contrary to the Agreement, implement any such agreement notwithstanding domestic time limits, and may communicate directly or use a Commission for oral exchanges to resolve interpretive or application issues and eliminate double taxation.

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