Mutual agreement procedure enables competent authorities to resolve treaty taxation disputes and implement agreements beyond domestic time limits.

The Mutual Agreement Procedure permits a taxpayer to present a case to the competent authority within three years where taxation is not in accordance with the Agreement; the competent authority shall endeavour to resolve justified objections by mutual agreement with the other Contracting State and implement any agreement notwithstanding domestic time limits. Competent authorities must seek to resolve interpretation or application difficulties, may consult to eliminate unprovided cases of double taxation, communicate directly, and develop bilateral procedures while also adopting unilateral facilitative measures.

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