Are advance pricing agreements the transfer pricing controversy management tool of the future?

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Abstract

This article examines the worldwide changes that have taken place in relation to transfer pricing regulation and enforcement as a background to investigating the reasons for the rise in popularity of advance pricing agreements as a transfer pricing controversy management tool. It also considers various new developments impacting the effectiveness of these agreements, including the introduction of a new Advance Pricing Agreement Program by the Australian Tax Office in March 2011.
Original languageEnglish
Pages (from-to)222-234
Number of pages13
JournalAustralian Tax Review
Volume40
Issue number4
Publication statusPublished - 2011

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