Tony Healy writes:

It's misleading to represent transfer pricing as a problem caused by intellectual property rights, as Stephen Grenville does. Rather, it's a problem of corporate tax law and international treaties.

There are two important points. First, intellectual property rights allow corporates to profit from their work and holdings. The debate about transfer pricing is not about whether they're entitled to those profits, but about other customer countries gaining a fair share through tax. Second, most of the disputed revenue arises from transactions for services, such as ads, not royalties on patents.