Mutual agreement procedure enables taxpayers to present treaty disputes to competent authorities for binding bilateral resolution, including tax adjustments.

The mutual agreement procedure allows a person who believes taxation by one or both Contracting States is inconsistent with the Convention to present the case to the competent authority of residence or nationality within the Convention's time limit. The competent authority shall endeavour to resolve justified objections and, if necessary, conclude a bilateral agreement with the other competent authority to avoid treaty-inconsistent taxation. Competent authorities shall consult to resolve interpretation or application doubts, may eliminate double taxation, and may implement agreements affecting imposition, refund or credit of taxes notwithstanding domestic time limits.

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