ABSTRACT
I. The Proposal: Voluntary but Binding Arbitration of Transfer Pricing Disputes Involving MNEs under the Income Tax
The proposal advanced here is that there be set up a permanent board of arbitration for transfer pricing disputes involving multinational enterprises (MNEs) under income taxation. The sole assignment of the board would be to settle on a transfer price, which all parties to the dispute - typically, two countries' tax administrations, and the MNE - would be bound to use, once they had accepted the arbitration process. There would be no appeal. A dispute could be brought to the board either by the MNE (that is, by the parent company or one of its affiliates) or by anyone of the tax administrations.
