Mutual Agreement Procedure enables taxpayers to seek competent-authority resolution of treaty taxation disputes and binding mutual agreements.

The Mutual Agreement Procedure permits a person who believes actions by one or both Contracting States result in taxation not in accordance with the Agreement to present the case to the competent authority of his residence or nationality within three years of notification. The competent authorities shall endeavour to resolve justified objections by mutual agreement, implement any agreement despite domestic time limits, consult to resolve interpretive difficulties or eliminate double taxation, communicate directly, and may meet through a commission for oral exchanges.

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