Mutual agreement procedure enables competent authorities to resolve and prevent taxation inconsistent with the tax treaty through direct agreement.

A mutual agreement procedure permits a resident alleging taxation inconsistent with the Convention to present his case to his competent authority within three years of the relevant notice; that authority must, if the objection is justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid taxation contrary to the Convention, implement any agreement notwithstanding national time limits, and endeavour through direct communication or a representative Commission to resolve interpretive or application difficulties and eliminate double taxation.

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