Mandatory arbitration gains popularity in advance pricing agreement cases
January 28, 2009
A recent memorandum of understanding signed by the US and Germany has introduced a set of guidelines that set out how to utilise arbitration in advance pricing agreements.
Mandatory arbitration as a means of resolving double taxation disputes in general and transfer pricing issues in particular, is gaining support from the international community. This momentum is evident within the EU and the OECD, and in bilateral double taxation treaties. It is expected to become more common in treaties in the future.
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