Article 27 - Mutual Agreement Procedure

Mutual Agreement Procedure enables taxpayers to seek competent authority resolution for taxation inconsistent with the treaty.

Article 27 provides that a resident believing taxation to be inconsistent with the treaty may present a case to his competent authority within three years of notice; if justified and unresolved domestically, the competent authorities shall endeavour to reach a mutual agreement and implement it notwithstanding national time limits. Competent authorities must also consult to resolve interpretation or application difficulties, eliminate double taxation beyond the treaty's provisions, communicate directly, and may form a Commission for oral exchanges to reach agreement.