Mutual Agreement Procedure enables taxpayers to seek competent authority resolutions to prevent taxation not in accordance with a tax convention.

The Mutual Agreement Procedure allows a person who believes actions of one or both Contracting States will result in taxation not in accordance with the Convention to present the case to the competent authority of residence or nationality, within three years of first notification. The competent authority shall endeavour to resolve justified objections and, if necessary, reach a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Convention; such agreements are to be implemented notwithstanding domestic time limits. Competent authorities may consult directly, including via a joint commission, to resolve interpretation issues and eliminate double taxation.

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