Mutual Agreement Procedure allows taxpayers to seek competent authority resolution of treaty-based double taxation disputes by mutual agreement. A taxpayer may present a case to the competent authority of their State of residence or nationality within three years of first notification if actions by one or both Contracting States cause taxation inconsistent with the Agreement. The competent authority shall, if the objection appears justified and it cannot resolve the issue alone, endeavour to reach a mutual agreement with the other State's competent authority to avoid such taxation, and any agreement reached shall be implemented notwithstanding domestic time limits. Competent authorities shall also consult to resolve interpretation or application difficulties and may communicate directly, including through a joint commission.