Strategic Approach to Transfer Pricing Disputes Through Mediation under the MAP

Effective dispute resolution, efficiency, and legal certainty are crucial in the complex world of transfer pricing. This innovative book presents 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. 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. This book presents 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.