Mutual Agreement Procedure: taxpayers may seek competent authority negotiation to remedy treaty-inconsistent taxation.

A taxpayer believing that actions by one or both Contracting States result or will result in taxation contrary to the treaty may present the case to the competent authority of the State of residence or nationality within three years of first notification; the competent authority shall seek a mutual agreement with the other State's competent authority to avoid treaty-inconsistent taxation, implement any agreement notwithstanding domestic time limits, resolve interpretation or application difficulties, consult to eliminate double taxation not covered by the treaty, and communicate directly or through a joint commission.

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