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

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.