Mutual agreement procedure enables resolution of treaty-based taxation discrepancies through competent authority negotiation.

A resident may present a case to the competent authority of his State of residence if actions of one or both Contracting States result or will result in taxation not in accordance with the Convention; the competent authority shall, if the objection appears justified and it cannot itself resolve the matter, seek by mutual agreement with the other State's competent authority to avoid such taxation, implement any agreement notwithstanding national time limits, and endeavour to resolve interpretation or application issues or consult to eliminate double taxation, including by direct communication or a bilateral Commission.

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