Mutual Agreement Procedure enables taxpayers to seek bilateral competent authority resolution of tax treaty disputes and interpretation issues. Where a taxpayer considers that actions by one or both Contracting States will result in taxation not in accordance with the Agreement, the taxpayer may present the case to the competent authority of the State of residence or nationality within a specified procedural time limit. The competent authority shall, if the objection appears justified and cannot be resolved unilaterally, seek a mutual agreement with the other State to avoid taxation inconsistent with the Agreement, implement any agreement notwithstanding domestic time limits, and develop bilateral procedures and direct communication to resolve interpretative or application difficulties and eliminate double taxation.