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 mutual agreement procedure and advance pricing agreements, 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.