The ALP comes with deficiencies, and its application is highly complex. Specifically, transfer pricing via benchmark studies leads to a great deal of uncertainty and conflicts. However, no conclusive or viable alternative has been suggested to date. The integration of technology could help in this regard, and tax authorities and international organizations should take this approach into account to improve the current situation.
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Riedl et al. (Mon,) studied this question.
www.synapsesocial.com/papers/69df2b2ce4eeef8a2a6b01e2 — DOI: https://doi.org/10.59403/avvcb6
Andreas Riedl
Stefan Greil
International Transfer Pricing Journal
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