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  Transfer pricing Miscellaneous 2021

A new phase in transfer pricing dispute resolution in Australia

Source: National

Published Date: 9 Sep 2021

 

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This paper covers:

  • The role that your evidence can play in a domestic court strategy relative to a MAP strategy in light of Glencore
  • The impact of a multinational group's domestic dispute resolution strategy (i.e., to settle or to litigate) on potentially achieving a resolution via MAP/arbitration
  • For both the multinational taxpayer and the ATO, the tension between preserving rights under domestic tax laws and achieving resolution via MAP / arbitration
  • The impact of mandatory binding arbitration on the prospects of achieving resolution via MAP; and
  • The OECD's desire to change the dialogue from dispute resolution' to dispute prevention' and what this might mean for multinational groups' dispute resolution strategies in the future.
Author(s)

Individual Session

A new phase in transfer pricing dispute resolution in Australia

Author(s): Martin Fry FTI , Thomas Ickeringill
Materials from this session:

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