Problems of Transfer Pricing and Possibilities for its Simplification

This ICTD Research in Brief is a two-page summary of ICTD Working paper 86 by Sol Picciotto. This series is aimed at policy makers, tax administrators, fellow researchers and anyone else who is big on interest and short on time. The international system for taxation of the profits of multinational enterprises (MNEs) is deeply dysfunctional. The recent attempts at reform have only patched up the system, and alternative approaches should be considered (Picciotto 2017). In the meantime, developing countries sorely need practical guidance, especially on the methods for allocation of profits. These are known as transfer pricing rules.