Mutual agreement procedure allows taxpayers to seek competent authorities' direct negotiation to resolve treaty taxation conflicts and ensure implementation. A person who considers that actions of one or both Contracting States result or will result in taxation inconsistent with the Convention may present the case to the competent authority of residence or nationality within the Convention's prescribed time limit. The competent authority shall endeavour, if justified and unable to resolve the matter alone, to reach a mutual agreement with the other State's competent authority to avoid such taxation, and any agreement shall be implemented notwithstanding domestic time limits; competent authorities may also consult, communicate directly, and form a Commission for oral exchanges to resolve interpretation or application difficulties.