A widespread globalization and the on-going digitalization of economic activities raise new challenges for fiscal administrations. These two simultaneous phenomena make it hard to localize profits in the international value chains and in digital activities. Michel Taly, a fiscal lawyer and former head of the French tax legislation, and Pascal Saint-Amans (OECD) discuss the very nature of these issues and their conceivable solutions. The traditional price transfer method faces the changes of companies' business activities. Hence, it should be adapted at an international level. What is at stake are both the amount of taxes raised by governments and taxpayers legal certainty.