The study will primarily take the form of a comparative case study of the transfer pricing regimes in Indonesia, Vietnam, Nigeria and Uganda. The comparison will examine the state of Tax Policy disputes before the introduction of Advanced Pricing Agreement regimes in the respective countries as well as after the introduction.
In addition, through this study, the researchers aim to understand the difference between the amount of information necessary and available under the APA regime as compared to the data collected under TP audit and litigation. They aim also to draw a general picture of the type of taxpayers that opt to seek APAs in order to understand how sophisticated they are and if there is information asymmetry between the taxpayers and revenue administrators. They will also evaluate the link between tax administration resources for audit and MAP vis-a-vis the use of APAs. Finally, they will assess what general challenges tax administrators have faced while using the APA regime as well as positive outcomes. This will consider the implications of using unilateral, bilateral, and multilateral APAs.