Mutual agreement procedure enables taxpayers to seek resolution of treaty-inconsistent taxation through competent authorities and bilateral agreement implementation.

A person who believes actions of one or both Contracting States result in taxation inconsistent with the Agreement may present the case to the competent authority of residence or nationality; the competent authority shall, if justified and unable to resolve the matter alone, seek a mutual agreement with the other State to avoid treaty-inconsistent taxation, and any such agreement shall be implemented notwithstanding domestic time limits. Competent authorities shall also resolve interpretive doubts, consult to eliminate double taxation in unprovided cases, and may communicate directly or through a joint commission.

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