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          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

          Provisions expressly mentioned in the judgment/order text.

          <h1>Mutual Agreement Procedure allows taxpayers to seek bilateral resolution of treaty-based taxation mismatches through competent authorities and consultations.</h1> The Mutual Agreement Procedure allows a person who believes actions of one or both Contracting States cause taxation inconsistent with the Convention to present the case to the competent authority of his State of residence or nationality within three years of notification. The competent authority shall, if the objection appears justified and it cannot itself reach a solution, seek mutual agreement with the other State's competent authority to avoid treaty-inconsistent taxation and to resolve interpretation or application difficulties, including direct communications and oral exchanges via a commission if advisable.

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