International - The Effectiveness of Mutual Agreement Procedures as a Means for Settling International Transfer Pricing Disputes
- R. Biçer
- International Transfer Pricing Journal, 2014 (Volume 21), No 2
- 14 March 2014
This article addresses the current status quo of the mutual agreement procedure, tackling the various issues related to article 25 of the OECD Model Convention and the EU Arbitration Convention (90/436). Certain obstacles to a proper functioning of the MAP are also addressed, including the underlying reasons of why the MAP has been an ineffective process and double taxation persists even where a MAP is put in effect.