Mutual agreement procedure enables residents to seek relief from treaty-inconsistent taxation and for competent authorities to resolve double taxation.

A resident may present to the competent authority a case that actions of one or both Contracting States result in taxation inconsistent with the Agreement; the authority shall, if justified and unable to resolve it alone, endeavour to reach a mutual agreement with the other State to avoid such taxation and implement any agreement notwithstanding national time limits. Competent authorities shall also resolve interpretation or application difficulties, consult to eliminate double taxation beyond the Agreement, communicate directly, and where advisable conduct oral exchanges through representatives.

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