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Practical TP Dispute Resolution

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

 
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...

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