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Judicial Boundaries of Mutual Agreement Procedures and Advance Pricing Agreements: Lessons from Oracle, Refinitiv, AON and A Oy Cases

M.S. Screpante

International Transfer Pricing Journal2026https://doi.org/10.59403/1mcmh93article
ABDC C
Weight
0.50

What the paper says

The relationship between international transfer pricing mechanisms, particularly MAPs and APAs, and domestic litigation is examined in this article. By contrasting recent decisions in Australia ( Oracle ), India ( AON Consulting ), the United Kingdom ( Refinitiv ) and Finland ( A Oy ), it reveals divergent global trends concerning judicial deference and the legality of treaty-based agreements. The Finnish approach shows how treaty obligations might need changes to domestic legislation, even though most jurisdictions give priority to domestic legislative authorities. In order to bring together national and international dispute resolution, the article’s conclusion advises better treaty coordination and transparency.

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https://doi.org/https://doi.org/10.59403/1mcmh93

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@article{m.s.2026,
  title        = {{Judicial Boundaries of Mutual Agreement Procedures and Advance Pricing Agreements: Lessons from Oracle, Refinitiv, AON and A Oy Cases}},
  author       = {M.S. Screpante},
  journal      = {International Transfer Pricing Journal},
  year         = {2026},
  doi          = {https://doi.org/https://doi.org/10.59403/1mcmh93},
}

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Judicial Boundaries of Mutual Agreement Procedures and Advance Pricing Agreements: Lessons from Oracle, Refinitiv, AON and A Oy Cases

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Evidence weight

0.50

Balanced mode · F 0.40 / M 0.15 / V 0.05 / R 0.40

F · citation impact0.50 × 0.4 = 0.20
M · momentum0.50 × 0.15 = 0.07
V · venue signal0.50 × 0.05 = 0.03
R · text relevance †0.50 × 0.4 = 0.20

† Text relevance is estimated at 0.50 on the detail page — for your query’s actual relevance score, open this paper from a search result.