Mutual Agreement Procedure allows residents to seek treaty-based resolution of taxation disputes via competent authority negotiation.

Persons contesting treaty-inconsistent taxation may present their case to the competent authority of their State of residence or nationality within the prescribed notification period; the competent authority shall, if the objection appears justified and a domestic solution is unavailable, seek a mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Convention, with any agreement to be implemented notwithstanding domestic time limits.

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