Mutual agreement procedure allows taxpayers to seek competent authority resolution of treaty taxation conflicts and avoid inconsistent taxation.

Article 25 provides a Mutual Agreement Procedure whereby a person believing taxation contrary to the Agreement may present the case to the competent authority of his residence or nationality; that authority shall, if the objection appears justified and it cannot itself resolve the issue, endeavour to reach a mutual agreement with the other Contracting State's competent authority to avoid taxation inconsistent with the Agreement, with any such agreement implemented notwithstanding domestic time limits.

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