In this article from Global Tax Weekly, NERA Affiliated Consultant Dr. Alexander Voegele and Principal Philip de Homont present a case study demonstrating how the transfer pricing system for a highly integrated multinational corporation in the high-tech industry can be structured and communicated to tax authorities. The authors explain how highly integrated value chains with multiple non-routine companies can be remunerated through residual profit splits, and warn that care must be taken to communicate such systems to the tax authorities effectively.