Mutual Agreement Procedure: taxpayers may request competent authorities to resolve treaty-related taxation disputes through mutual agreement.

A Mutual Agreement Procedure allows a person who believes actions of one or both Contracting States result or will result in taxation inconsistent with the Agreement 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 by mutual agreement with the other State, implement any agreement notwithstanding domestic time limits, consult on interpretation or application issues, communicate directly, and, if advisable, hold oral exchanges through a Commission of representatives.

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