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Mutual Agreement Procedure enables competent authorities to resolve treaty-inconsistent taxation through negotiated agreement and consultations. Mutual Agreement Procedure permits a resident or applicable national to present a case to the competent authority within three years from first notification if treaty-inconsistent taxation arises. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid such taxation, implementing any agreement notwithstanding domestic time limits. Competent authorities shall also endeavour to resolve interpretation or application difficulties, consult to eliminate double taxation beyond the Agreement, and may communicate directly or exchange opinions orally through representatives to reach agreement.
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Provisions expressly mentioned in the judgment/order text.
Mutual Agreement Procedure enables competent authorities to resolve treaty-inconsistent taxation through negotiated agreement and consultations.
Mutual Agreement Procedure permits a resident or applicable national to present a case to the competent authority within three years from first notification if treaty-inconsistent taxation arises. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid such taxation, implementing any agreement notwithstanding domestic time limits. Competent authorities shall also endeavour to resolve interpretation or application difficulties, consult to eliminate double taxation beyond the Agreement, and may communicate directly or exchange opinions orally through representatives to reach agreement.
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