The OECD’s Base Erosion and Profit Shifting (BEPS) effort has resulted in many changes in global transfer pricing systems. Rapid developments in the business world, generally and currently caused by the corona crisis, make it necessary to constantly review and, if necessary, adjust transfer pricing systems. As a result, multinational enterprises more and more opt for transfer pricing methods such as the Profit Split Method using a residual analysis (RPSM). In the context of cross-border transfer pricing and the ongoing digitalisation process emphasis is placed on platform concepts.
