Mutual Agreement Procedure enables taxpayers to seek competent authority resolution of treaty-based double taxation disputes by bilateral agreement. The Mutual Agreement Procedure allows a taxpayer to present to the competent authority of the State of residence (or nationality where applicable) a case that actions by one or both Contracting States result or will result in taxation not in accordance with the Agreement, within three years of first notification. If the competent authority finds the objection justified but cannot resolve it unilaterally, it shall seek a mutual agreement with the other State's competent authority to avoid such taxation, and any agreement reached shall be implemented notwithstanding domestic time limits.