Mutual agreement procedure enables residents to seek competent authority resolution of treaty-inconsistent taxation through direct negotiation.

A resident who considers that actions of one or both Contracting States result or will result in taxation not in accordance with the Agreement may present the case to the competent authority of the Contracting State of residence within the specified period. If the competent authority finds the objection justified and cannot itself resolve it, it shall endeavour to resolve the case by mutual agreement with the other State's competent authority to avoid taxation not in accordance with the Agreement; any agreement reached shall be implemented notwithstanding national time limits.

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