Mutual Agreement Procedure enables taxpayers to seek competent authority negotiations to avoid treaty-inconsistent taxation.

The Mutual Agreement Procedure permits a taxpayer to present to the competent authority a case that a Contracting State's actions result or will result in taxation inconsistent with the treaty, irrespective of domestic remedies and within a prescribed time limit. If the authority deems the objection justified and cannot itself resolve it, it shall seek a mutual agreement with the other State's competent authority to avoid improper taxation; competent authorities must endeavour to resolve interpretive or application difficulties, may consult to eliminate double taxation, and may communicate directly to reach agreements.

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