Article 25 - Mutual Agreement Procedure

Mutual Agreement Procedure lets residents request competent-authority resolution of treaty taxation mismatches within the treaty's time limit.

The Mutual Agreement Procedure allows a resident to present a case to their competent authority if taxation is or will be inconsistent with the Agreement, subject to the treaty's time limit; the competent authority shall endeavour to resolve justified claims with the other State's authority and implement any solution notwithstanding national time limits. Competent authorities must jointly resolve application doubts, may consult to eliminate double taxation, may communicate directly, and the MLI Article 16 mutual agreement obligation applies.