Mutual Agreement Procedure secures taxpayer recourse for treaty-inconsistent taxation; competent authorities must seek resolution by mutual agreement.

A Mutual Agreement Procedure permits a person who believes taxation is inconsistent with a Covered Tax Agreement to present the case to a competent authority within a three-year period; competent authorities must endeavour to resolve justified objections by mutual agreement and implement agreements notwithstanding domestic time limits. The provision sets default rules on venue, time limits, authority duties and consultation, allows Parties to enter specified reservations, and requires notifications to the Depositary to determine whether treaty provisions are replaced or superseded.

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