Mutual agreement procedure preserves taxpayers' right to resolve treaty taxation disputes through competent authority negotiations.

A taxpayer may present a case to the competent authority of residence or nationality within three years of first notification if actions produce taxation contrary to the Agreement; the competent authority shall seek a mutual agreement with the other State's authority to remove such taxation and implement any agreement notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretation issues, consult on eliminating double taxation beyond the Agreement's provisions, communicate directly, and may use a Commission for oral exchanges to reach agreement.

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