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

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.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2026-02-18
DOI
https://doi.org/10.59403/1mcmh93
Primary Topic
World Trade Organization Law
Type
article
Field-Weighted Citation Impact
0.00
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article

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 Journal
World Trade Organization Law
article

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

M.S. Screpante
article en

Abstract

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.

International Transfer Pricing JournalVol. 33(2)
Openalex Percentile: Top 54%
World Trade Organization Law
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