Mutual Agreement Procedure enables taxpayers to seek competent authorities' negotiation to resolve treaty-based taxation inconsistencies. A taxpayer alleging taxation contrary to the Agreement may present the case to the competent authority of residence or nationality within the prescribed period; that authority, if it deems the objection justified and cannot itself resolve it, shall seek a mutual agreement with the other Contracting State's competent authority to eliminate taxation not in accordance with the Agreement, and any agreement reached shall be implemented notwithstanding domestic time limits.