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Clark Armitage Chairs Competent Authority Panel at USD Transfer Pricing Symposium

May 9, 2019, 11:00 AM PT
Chair:J. Clark Armitage
Program:Competent Authority
Event Sponsor:6th Annual University of San Diego Transfer Pricing Symposium
Where:

Joan B. Kroc Institute for Peace and Justice, Theatre
University of San Diego
Kroc Institute for Peace and Justice (KIPJ) Building, Suite 121
5998 Alcalá Park
San Diego, CA 92110-2492

Registration:Click Here To Register

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.

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