Taxable persons facing a transfer pricing adjustment may apply to their country of residence to resolve any problems with the imposition of double taxation that may result from that transfer pricing adjustment. It is important that it provides for a mandatory and binding arbitration mechanism to eliminate double taxation by referring to the opinion of an independent advisory body if the competent authorities do not reach an agreement after two years. This went beyond the bilateral treaties that entered into force at the time, which simply required the competent authorities to make their “best efforts” to eliminate double taxation. . . .