This article examines the holistic transfer pricing approach that a number of countries have been implementing into their laws following the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative. In this context, a value chain analysis (VCA) approach aligns business models, finance and tax positions and the governance of multinational enterprises (MNEs) with best practice under the OECD/G20 BEPS initiative.