Group Synergies and the Shapley Value Analysis: A Game Theory Approach
Journal
Country
International
Published Date
Issue
International Transfer Pricing Journal 2017 (Volume 24), No. 5
Document
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.