Mutual agreement procedure: arbitration and consultations resolve treaty taxation mismatches when competent authorities cannot agree. Article 25 establishes the Mutual Agreement Procedure allowing a person who faces taxation not in accordance with the Convention to present a case to a competent authority; competent authorities must endeavour to resolve justified objections by mutual agreement, may consult directly or through a joint commission, and any agreement is to be implemented notwithstanding domestic time limits. The OECD text provides for arbitration when authorities cannot agree within the prescribed period, while the UN model offers alternatives with and without arbitration and allows bilateral development of implementation procedures.