Mutual agreement procedure allows taxpayers to request competent authorities to resolve treaty-based taxation mismatches through negotiation.

A person believing that actions of one or both Contracting States produce taxation contrary to the Agreement may present the case to the competent authority of residence or nationality within three years of first notification. 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 taxation not in accordance with the Agreement, and any agreement reached shall be implemented notwithstanding domestic time-limits. Competent authorities shall also endeavour to resolve interpretive doubts, consult to eliminate double taxation not covered by the Agreement, communicate directly, and may use a joint commission for oral exchanges.

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