INSIGHT: Transfer Pricing Challenges In the Digital Economy—Part 1: Hic Sunt Dracones? [read]

Posted May 30, 2019, 4:00 PM

There be dragons in the OECD’s BEPS project, which mandated that transfer pricing outcomes under the arm’s-length standard should be aligned with value creation. In the digital economy, new business models are challenging transfer pricing practitioners on how best to apply the value creation approach. In a two-part series Lorraine Eden of Texas A&M and Niraja Srinivasan and Srini Lalapet of Dell Technologies illustrate the complexity of digital business models and the challenges they create for conducting transfer pricing analysis.

 

INSIGHT: Transfer Pricing Challenges In the Digital Economy—Part 2: A Case Study of the Internet of Things [read]

Posted May 31, 2019, 4:01 PM
 
The OECD's BEPS project mandated that transfer pricing outcomes under the arm's-length standard should be aligned with value creation. In the digital economy, new business models are challenging transfer pricing practitioners on how best to apply the value creation approach. In a two-part series Niraja Srinivasan and Srini Lalapet of Dell Technologies and Lorraine Eden of Texas A&M illustrate the complexities and challenges posed by digital business models. The first article explored the digital economy and the OECD’s work on BEPS Action Item 1 (taxing in the digital economy). This second article is a case study of the Internet of Things (IoT), which builds and uses a stylized transfer pricing analysis to explore the transfer pricing challenges posed by an IoT ecosystem.