Mutual Agreement Procedure: taxpayers can seek treaty relief and competent authorities must endeavour mutual resolution and implementation.

A person may present to the competent authority a case that actions of one or both Contracting States cause taxation not in accordance with the DTAA; under the MLI the case must be presented within three years of first notification. Competent authorities shall endeavour to resolve justified objections by mutual agreement and implement agreements presented within the period notwithstanding domestic time limits. Authorities may consult to resolve interpretive doubts, eliminate double taxation in unprovided cases, communicate directly, and use a Commission for oral exchanges.

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