The crucial point here is that formula apportionment and separate entity
accounting were seriously considered as potential solutions at the time,
and it was recognized that the indeterminacy of arm’s length transfer
pricing creates leeway for tax minimization (Graetz, 2003: 403–7). Ultimately,
however, governments were unwilling to agree on UT+FA and
thus openly address the distributive conflict over the allocation of the tax
base. The ALS was perceived as a solution capable of de-politicizing this
conflict (Picciotto, 1992: 172). The provisions of the allocation convention
are still the essence of today’s transfer pricing rules.