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This article examines the growing incidence and complexity of international tax disputes, with particular emphasis on transfer pricing, drawing on survey evidence and economic, in particular business tax research. It assesses existing dispute prevention and resolution mechanisms, and offers practical recommendations for firms, tax administrations and policymakers to enhance tax certainty through greater cooperation, effective use of technology and more efficient procedural frameworks.
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Schmalenbach-Gesellschaft 'Transfer Pricing' Working Group (2026) studied this question.
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