Mutual Agreement Procedure lets taxpayers seek competent authorities' mutual resolution of treaty-based taxation mismatches.

Mutual Agreement Procedure permits a person alleging taxation contrary to the Convention to present the case to the competent authority of residence or nationality within three years of first notification. If the competent authority considers the objection justified but cannot itself resolve it, it shall endeavour to reach a mutual agreement with the other State's competent authority to avoid taxation inconsistent with the Convention, and any such agreement shall be implemented notwithstanding domestic time limits. Competent authorities may also consult to resolve interpretation issues, eliminate unprovided double taxation, communicate directly, and use a Commission for oral exchanges.

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