Resolving Multilateral Transfer Pricing Disputes under the Current Tax Treaty and European Frameworks: Shortcomings and Possible Suggestions for Improvement

Over the past years, the number of transfer pricing disputes has been growing exponentially, while their nature is becoming more complex and multilateral. These trends are only expected to further intensify in the future. This article examines to what extent the currently available international and European dispute resolution frameworks, which have traditionally focused on bilateral dispute resolution, could be used by taxpayers and competent authorities to also resolve multilateral transfer pricing disputes in an effective and adequate manner.