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What are 2 options to resolve a tax/transfer pricing dispute?

Transfer Pricing
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Tax Professional Answers

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Michael Kalson, PhD
Transfer pricing dispute resolution can be achieved in advance of controlled transactions through the use of advanced pricing arrangements consisting of negotiations that determine an appropriate set of criteria for the pricing of those transactions over a fixed period of time. One can also seek assistance available under the applicable tax treaties through the mutual agreement procedures provided by the Office of the Competent Authority within the relevant tax administration.
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