The number of tax disputes is increasing rapidly around the world. The trend is encouraging governments to turn to alternative dispute resolution (ADR) in a bid to reduce backlogs in the courts. While ADR is well established in some jurisdictions, in others it is just getting going. Aaran Fronda looks at how ADR has become an increasingly viable solution for resolving tax disputes.
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Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default