I have been associated with Alfred Storck for many years through occasional academic collaboration. It was a special honor and pleasure for me to be appointed Co-Chairman of the Transfer Pricing Center at the Institute for International Tax Law at the WU Vienna University of Economics and Business Administration in January 2018. Over at least the last ten years, Alfred has enriched the academic work at the Institute for International Tax Law and has provided substantial support so that the Transfer Pricing Center has been able to develop outstandingly. Furthermore, his commitment and energy for the TPI is a result of this very successful work. It is an honor for me to dedicate the attached article to him on current developments in the practical implementation of transfer prices in MNE.

The key elements for the successful execution of a transfer pricing (TP) system are the compliant implementation of the fundamental theory of transfer pricing and the resolution of TP conflicts. In order to be compliant, fundamental design considerations are required in the conception and implementation of ...