“…As an instrument that covers a broad range of transactions, ATRs must be distinguished from Advance Pricing Agreements (APAs), i.e., international ex ante bilateral or multilateral agreements between taxpayers and tax authorities on transfer pricing problems arising from crossborder transactions (De Waegenaere, Sansing, and Wielhouwer, 2007;Becker, Davies, and Jakobs, 2014; for an overview see Vollert, Eikel, and Sureth, 2013 Reinganum and Wilde, 1986); Erard and Feinstein, 1994). Therefore, the parties play a reporting game when not applying for an APA.…”