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Using Bilateral Advance Pricing Agreements to Resolve Tax Transfer Pricing Disputes

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  • De Waegenaere, Anja
  • Sansing, Richard
  • Wielhouwer, Jacco L.

Abstract

We investigate the use of bilateral advance pricing agreements (BAPAs) to resolve transfer pricing disputes between a taxpayer and two tax authorities. BAPAs are designed to protect firms from double taxation while reducing expected compliance costs. We identify settings in which we expect BAPAs to arise and investigate the effect of the program on compliance costs. We show that agreements are more likely to arise when the amount of income potentially subject to double taxation is low and the difference in tax rates between the two countries is high. We also show that the BAPA program can increase compliance costs.

Suggested Citation

  • De Waegenaere, Anja & Sansing, Richard & Wielhouwer, Jacco L., 2007. "Using Bilateral Advance Pricing Agreements to Resolve Tax Transfer Pricing Disputes," National Tax Journal, National Tax Association;National Tax Journal, vol. 60(2), pages 173-191, June.
    • Handle: RePEc:ntj:journl:v:60:y:2007:i:2:p:173-91
    DOI: 10.17310/ntj.2007.2.01
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    File URL: https://doi.org/10.17310/ntj.2007.2.01
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    Cited by:

    1. Chen, An & Hieber, Peter & Sureth, Caren, 2022. "Pay for tax certainty? Advance tax rulings for risky investment under multi-dimensional tax uncertainty," arqus Discussion Papers in Quantitative Tax Research 273, arqus - Arbeitskreis Quantitative Steuerlehre.
    2. Dyck, Daniel & Lorenz, Johannes & Sureth, Caren, 2022. "How do tax technology and controversy expertise affect tax disputes?," arqus Discussion Papers in Quantitative Tax Research 274, arqus - Arbeitskreis Quantitative Steuerlehre.
    3. Becker, Johannes & Davies, Ronald B. & Jakobs, Gitte, 2017. "The economics of advance pricing agreements," Journal of Economic Behavior & Organization, Elsevier, vol. 134(C), pages 255-268.
    4. Alex A. T. Rathke & Amaury J. Rezende & Christoph Watrin & Rafael M. Antônio, 2023. "Profit shifting and the attractiveness of Advance Pricing Agreements," Journal of Business Economics, Springer, vol. 93(5), pages 817-857, July.
    5. Diller, Markus & Lorenz, Johannes, 2017. "Do tax information exchange agreements curb transfer pricing-induced tax avoidance?," Passauer Diskussionspapiere, Betriebswirtschaftliche Reihe B-29-17, University of Passau, Faculty of Business and Economics.
    6. De Waegenaere, Anja & Sansing, Richard, 2010. "Inconsistent Transfer Prices and the Location of Mobile Capital," National Tax Journal, National Tax Association;National Tax Journal, vol. 63(4), pages 1085-1109, December.
    7. Kortebusch, Pia, 2014. "Should multinational companies request an advance pricing agreement (APA) - or shouldn't they?," arqus Discussion Papers in Quantitative Tax Research 173, arqus - Arbeitskreis Quantitative Steuerlehre.

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