Mutual Agreement Procedure enables competent authorities to resolve treaty-inconsistent taxation and implement agreements to avoid double taxation.

A Mutual Agreement Procedure allows a person who believes actions by one or both Contracting States will cause taxation inconsistent with the Convention to present the case to the Competent Authority of residence or nationality, within three years of first notification. The Competent Authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's Competent Authority to avoid taxation not in accordance with the Convention, implement any agreement notwithstanding domestic time limits, resolve interpretive difficulties, and communicate directly to reach agreements.

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