Mutual Agreement Procedure enables treaty dispute resolution by competent authorities and binding arbitration if negotiations fail.

A taxpayer may present to either competent authority an objection that actions of one or both Contracting States cause taxation inconsistent with the Convention within the specified time limit. Competent authorities must endeavour to resolve justified objections by mutual agreement, implement any agreement notwithstanding domestic time limits, consult on interpretive difficulties, and may communicate directly. If authorities cannot resolve the case within the subsequent negotiated period after all required information is provided, the taxpayer may request that unresolved issues be submitted to binding arbitration, unless those issues were decided by a domestic court; arbitration decisions bind both States and are to be implemented.

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