Mutual Agreement Procedure enables arbitration to resolve treaty taxation disputes when competent authorities cannot agree. The Mutual Agreement Procedure permits a person who believes taxation under a Convention is inconsistent with its provisions to present a case to competent authorities, which must seek a mutual agreement to remedy such taxation and may suspend assessment and collection during proceedings. If authorities cannot agree, a taxpayer may seek arbitration subject to procedural conditions, confidentiality undertakings, and exclusions where a domestic court has decided the matter. Arbitration is conducted by a three-member independent panel selecting between proposed resolutions limited to monetary dispositions or threshold determinations, with the written panel determination binding on the States if accepted by all concerned persons.