Mutual Agreement Procedure enables taxpayers to seek competent-authority negotiation to resolve cross-border tax inconsistencies.

A person believing that actions of one or both Contracting States result in taxation inconsistent with the Convention may present the case to the competent authority of the State of residence or nationality within three years from first notification. The competent authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other State's competent authority to avoid improper taxation, implement any agreement despite domestic time limits, resolve interpretive doubts, consult on elimination of double taxation, communicate directly, and use a Commission for oral exchanges if advisable.

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