Quantifying Options Realistically Available with Cooperative Game Theory
New
Journal
Country
International
Published Date
Issue
International Transfer Pricing Journal 2026 (Volume 33), No. 4
Document
The impact of options realistically available in (hypothetical) transfer pricing negotiations can be quantified to determine arm’s length profit splits and transaction values. This is achieved by the “component-efficient Shapley value”, an extension of the Shapley value that explicitly accounts for outside options. The approach is illustrated through stylized transfer pricing examples, including profit splits and business restructurings.