Mutual Agreement Procedure enables competent authorities to resolve treaty-inconsistent taxation through mutual agreement and direct cooperation.

Mutual Agreement Procedure allows a taxpayer to present a case to the competent authority of his residence or nationality when actions of one or both Contracting States produce taxation inconsistent with the Agreement; the authority shall endeavour to resolve justified objections by mutual agreement with the other State, implement any agreement notwithstanding domestic time limits, consult on interpretation or application issues, communicate directly, and, if needed, exchange opinions through a Commission of representatives.

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