Mutual Agreement Procedure enables taxpayers to seek treaty-based resolution when taxation contradicts the tax treaty.

Where a taxpayer alleges taxation not in accordance with the treaty, the Mutual Agreement Procedure allows presentation of the case to the competent authority of the taxpayer's State 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 treaty-inconsistent taxation, and any agreement reached must be implemented regardless of domestic time limits. Competent authorities must also consult to resolve interpretive doubts, eliminate double taxation beyond the treaty, and may communicate directly or through a joint commission to reach such agreements.

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