The EU Joint TP Forum (JTPF) has recently issued the draft paper on the “Application of the Profit Split Method within the EU”. The main purpose of this document is to address two issues: (1) when it is appropriate to apply the Profit Split Method (PSM), and (2) the use of profit splitting factors. This paper is an attempt to address these issues with the aim to explore how the application of the PSM could be simplified.
