Problems, Practical Implications and Proposed Solutions.
National tax authorities individually determine multinational ﬁrms’ country-speciﬁc tax liabilities by applying one or more sanctioned transfer pricing methodologies.
These methodologies are founded on basic assumptions about market structure and ﬁrm behavior that are rarely empirically valid. Moreover, for the most part, the transfer pricing methodologies now in vogue were developed before the Internet became a dominant factor in the world economy, and hedge and private equity funds transformed ﬁnancial and commodities markets. For these reasons, multinational ﬁrms are unable to accurately anticipate their tax liabilities in individual countries, and remain at risk of double taxation.