Mutual Agreement Procedure provides cross-border taxpayers a mechanism to resolve treaty-based taxation conflicts through competent authorities. The Mutual Agreement Procedure permits a person who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention to present the case to the competent authority of his State of residence or nationality within three years of the first notification. The competent authority shall endeavour, if the objection appears justified and it cannot itself resolve the matter, to reach a mutual agreement with the other Contracting State's competent authority to avoid taxation contrary to the Convention; such agreements are to be implemented notwithstanding domestic time-limits.