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Strategic Approach to Transfer Pricing Disputes through Mediation under the MAP

Strategic Approach to Transfer Pricing Disputes through Mediation under the MAP

Author: Leticia Cristofolini
Publisher: Kluwer Law International
ISBN: 9789403521695
Published In: July 2025
Format: Hardback
Jurisdiction: Netherlands ? Disclaimer:
Countri(es) stated herein are used as reference only

List Price: HKD 1,910.63

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Description
Contents

Details

Strategic Approach to Transfer Pricing Disputes through Mediation under the MAP is an innovative book presenting a structured framework for incorporating mediation into the Mutual Agreement Procedure (MAP), offering a solution for satisfactory, speedy, and fair settlements. In this context, the author analyzes the challenges of resolving transfer pricing disputes, assesses existing mechanisms, and demonstrates ways to overcome the MAP’s constraints and achieve better settlements for both taxpayers and tax administrations.

What’s in this book:

Aspects of transfer pricing and dispute resolution covered include:

transfer pricing risk management
compliance with diverse transfer pricing regulations across different jurisdictions
alignment with the arm’s length principle
critical evaluation of the MAP’s shortcomings
establishment of clear deadlines for MAP stages
elimination of upfront payment of challenged taxes
selection of mediators with expertise in transfer pricing, and
provisions safeguarding confidentiality throughout the procedure

Based on these insights, the author advocates for key changes in domestic laws and policies of countries to enhance flexibility in navigating transfer pricing disputes in the most efficient, satisfactory, and cost-effective manner.

How this will help you:

This book furnishes a comprehensive and systematic framework, designed to benefit jurisdictions, taxpayers, and tax professionals seeking more certainty and a more transparent, simplified, and efficient approach to dispute resolution. Tax professionals, legal practitioners, policymakers, tax authorities, and multinational enterprises will all discover a transparent and inclusive dispute resolution framework that guarantees superior results and ensures more effective implementation of international tax standards while enabling states to collect their fair share of taxes within the evolving international tax landscape.

List of Abbreviations

Preface

Acknowledgments

Introduction

CHAPTER 1. ADR Mechanisms for Resolving International Transfer Pricing Conflicts

CHAPTER 2. The Permanence of Transfer Pricing Conflicts under the Current ADR Mechanisms

CHAPTER 3. A More Inclusive and Transparent Enhancement Proposal for the Map: Mediation as an Alternative?

CHAPTER 4. Reformulating the Map: Including Mediation as an ADR Mechanism for Transfer Pricing Conflicts

Conclusions

Bibliography

Table of Cases