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Issue Number
06-021
In these times of growing global tax controversy, taxpayers face an increased need to carefully consider their options for resolution of cross-border tax disputes. Traditionally, the competent authority process, or mutual agreement procedure (MAP) available under bilateral tax treaties has been a reliable, effective mechanism for resolving double taxation or other treaty disputes. And advance pricing arrangements, as a tool to prevent disputes between taxpayers and authorities, have been, and continue to be, a valuable alternative in the transfer pricing context.
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