Mutual agreement procedure enables residents to seek competent-authority negotiation to prevent taxation inconsistent with the tax treaty.

A resident believing they face taxation contrary to the Agreement may present the case to their competent authority, which shall, if justified and unable to resolve it unilaterally, seek a mutual agreement with the other State's competent authority to avoid such taxation. Agreed resolutions shall be implemented despite domestic procedural limits if the other authority is notified within the Agreement's time frame. Competent authorities must endeavour to resolve interpretive or application doubts, consult to remove double taxation, communicate directly, and may use a Commission for oral exchanges.

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