Mutual agreement procedure allows residents to seek competent authority resolution of treaty-inconsistent taxation, producing binding agreements overriding national time limits.

A resident may present to the competent authority of his State a case that actions by one or both Contracting States cause taxation inconsistent with the Agreement. The competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek a mutual agreement with the other State's competent authority to avoid such taxation; any agreement reached shall be implemented notwithstanding national time limits. Competent authorities shall also endeavour to resolve interpretative or application doubts, consult to eliminate double taxation not covered by the Agreement, communicate directly, and may use a Commission for oral exchanges.

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