Mutual agreement procedure enables taxpayers to seek resolution via competent authority when taxation conflicts with treaty provisions.

Mutual agreement procedure allows a resident who alleges taxation not in accordance with the Convention to present the case to their competent authority, which shall, if the objection appears justified and it cannot resolve the matter alone, seek a mutual agreement with the other Contracting State to avoid taxation inconsistent with the Convention; competent authorities shall also endeavour to resolve interpretive or application difficulties and may communicate directly to reach such agreements.

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