Mutual Agreement Procedure allows residents to seek treaty relief and requires authorities to resolve cross border tax disputes.

A resident may present to its competent authority, within a three year period from the first notice, a case that actions by one or both Contracting States cause taxation not in accordance with the Convention; the competent authority shall endeavour, if justified and unable to act alone, to resolve the case by mutual agreement with the other State's competent authority, and any agreement shall be implemented notwithstanding national time limits, with authorities empowered to communicate directly to resolve interpretation or application doubts.

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