With the globalization and expansion of business of multinational enterprises

transfer pricing has become a key issue in the field of international taxation. This paper discusses the theory and practice of value chain analysis in transfer pricing

and takes the transfer pricing case of Coca-Cola Company as a typical case to analyze the application and importance of value chain analysis in it. It is found that value chain analysis can help to accurately determine the reasonableness of profit distribution of multinational enterprises

and effectively prevent the problems of tax base erosion and profit shifting. However

it also faces many challenges in the process of its application

and requires the cooperation of all parties to improve the transfer pricing management system and safeguard the tax rights and interests of all countries.