That the problem of under-taxation was acknowledged is evidenced
by the fact that tax administrations may correct the transfer prices set
by businesses by using ‘fractional methods’, i.e. formula apportionment,
for those cases where the ALS yields indeterminate results (Wang, 1945:
77–81). Since it was considered impossible to come to agreement on a
general formula, profit shifting was to be tackled case-by-case through
cooperation among national administrations whenever difficulties arose
(Picciotto, 1992: 183–85). What governments could not foresee was that
the sheer magnitude of multinational activity, and the increasing importance
of intangible assets would one day overburden tax administrations’
capacities of effective enforcement.