Simple Solutions for Complex Transfer Pricing Cases: A Possible Comeback of Rules of Thumb?

Journal
Riedl, A.; Protas, O.
International
International Transfer Pricing Journal 2019 (Volume 26), No. 4
PriceUSD 45

Multinational enterprises with a digital business model represent an increasingly important business type with challenging value chains. The recent OECD attempts are aiming to methodologically tackle the transfer pricing issues arising from these value chains – but did not come up with satisfying results, yet. This article discusses these developments and compares complex transfer pricing approaches to rules of thumb, finding that simplistic solutions can offer promising and efficient improvements also for complex (digital) scenarios.