Mutual Agreement Procedure enables taxpayers to seek competent authority negotiation to remedy taxation inconsistent with a tax treaty. Mutual Agreement Procedure allows a resident to present a case to the competent authority when actions by one or both Contracting States result in taxation not in accordance with the treaty; presentation must comply with the MLI's three year notification rule. If the competent authority finds the objection justified and cannot resolve it alone, it shall seek a mutual agreement with the other State to avoid taxation inconsistent with the Agreement, and any agreement reached must be implemented notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretative or application difficulties, may form a commission for oral exchanges, consult to eliminate double taxation in unprovided cases, and may communicate directly to apply the Agreement.