International - Group Synergies and the Shapley Value Analysis: A Game Theory Approach
- S. Batrakova; A. Hoefele
- International Transfer Pricing Journal, 2017 (Volume 24), No 5
- 2 October 2017
The OECD Transfer Pricing Guidelines acknowledge the importance of accounting for MNE group synergies for transfer pricing purposes. This article proposes a practical game theory approach to arrive at an equitable distribution of the profits related to group synergies between members of an MNE group, based on the measurable contribution of the parties.