Mutual Agreement Procedure allows residents to seek competent authority resolution of treaty-inconsistent taxation and bilateral agreement implementation. The Mutual Agreement Procedure allows a resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Convention to present the case to the competent authority of his State of residence within three years; the competent authority shall endeavour to resolve justified objections and, if necessary, seek a mutual agreement with the other Contracting State to avoid treaty-inconsistent taxation, implementing any agreement notwithstanding domestic time limits.