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<h1>Mutual agreement procedure enables competent authorities to resolve treaty taxation conflicts and eliminate double taxation.</h1> A person who considers that actions of one or both Contracting States cause taxation inconsistent with the Agreement may present the case to the competent authority of their State of residence or nationality within the prescribed time. If the competent authority finds the objection justified but cannot resolve it alone, it shall seek a mutual agreement with the other State's competent authority to avoid such taxation; any mutual agreement reached shall be implemented notwithstanding domestic time limits. Competent authorities must endeavour to resolve interpretive or application difficulties, consult to eliminate double taxation beyond the Agreement, and may communicate directly.
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