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          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

          Provisions expressly mentioned in the judgment/order text.

          <h1>Mutual Agreement Procedure enables taxpayers to seek treaty corrective relief, with agreements implemented despite domestic time limits.</h1> Article 27 provides a Mutual Agreement Procedure allowing a resident to present to the competent authority a case where taxation is not in accordance with the Convention; MLI Article 16 requires presentation within three years of first notification and directs competent authorities to endeavour to resolve justified objections by mutual agreement. Any MAP agreement shall be implemented notwithstanding domestic time limits, and competent authorities may consult or communicate directly to eliminate double taxation or resolve interpretation or application issues.

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