Mutual Agreement Procedure enables taxpayers to seek cross border resolution and binding competent authority agreements implemented despite domestic time limits. The Mutual Agreement Procedure permits a person who contends that actions by one or both Contracting States cause taxation contrary to the Agreement to present the case to the competent authority of residence or nationality within three years of first notification. The competent authority shall, if justified and unable to resolve the issue domestically, seek a mutual agreement with the other State to avoid improper taxation and shall implement any agreement notwithstanding domestic time limits. Competent authorities must also endeavour to resolve interpretation or application issues, consult to eliminate uncaptured double taxation, communicate directly, and may use a Commission for oral exchanges.