John Hobster and Gary J Mills from London and Bob Ackerman and Kathryn O'Brien from Washington DC all of Ernst & Young LLP's Transfer Pricing Controversy practice discuss transfer pricing dispute resolution
This article explores recent trends and developments in transfer pricing dispute resolution. Specifically it focuses on the technical framework and practical observations on an important mechanism available to multinational corporations (MNCs) to mitigate and manage their exposure to economic double taxation. This is the Mutual Agreement Procedure (MAP) also anecdotally known as Competent Authority (CA) as it is to the appointed Competent Authority of a particular state that a claim is made.
We will outline the technical framework under which these dispute resolution processes exist...
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John Hobster and Gary J Mills from London and Bob Ackerman and Kathryn O'Brien from Washington DC all of Ernst & Young LLP's Transfer Pricing Controversy practice discuss transfer pricing dispute resolution
This article explores recent trends and developments in transfer pricing dispute resolution. Specifically it focuses on the technical framework and practical observations on an important mechanism available to multinational corporations (MNCs) to mitigate and manage their exposure to economic double taxation. This is the Mutual Agreement Procedure (MAP) also anecdotally known as Competent Authority (CA) as it is to the appointed Competent Authority of a particular state that a claim is made.
We will outline the technical framework under which these dispute resolution processes exist...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
