Are advance pricing agreements the transfer pricing controversy management tool of the future?
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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 Arrangement Program by the Australian Taxation Office in March 2011.
This document has been peer reviewed.