Mutual agreement procedure enables competent authorities to resolve treaty taxation disputes by negotiation and implement agreements irrespective of domestic time limits. A resident may present to the competent authority a case that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention, within three years of first notification. The competent authority shall endeavour, if the objection appears justified, to resolve the case by mutual agreement with the other State's competent authority and implement any agreement notwithstanding domestic time limits. Competent authorities shall consult to resolve interpretation or application difficulties, may eliminate double taxation beyond the Convention, communicate directly, and use a Commission for oral exchanges when advisable.