Clark Armitage Chairs Competent Authority Panel at USD Transfer Pricing Symposium
This session demonstrates a government-to-government negotiation session involve the U.S. Competent Authority Analysts and the "Country X" representatives. The negotiators will use a hypothetical fact pattern, in connection with the MAP article of the U.S. Model Treaty, in order to demonstrate the key considerations in each country's respective negotiating positions. Time permitting, the participants will comment upon the impact (if any) of the potential for treaty-based arbitration, on their desires and efforts to obtain a mutual agreement.