Addressing the Tax Challenges of the Digitalization of the Economy – A Possible Answer in the Proper Application of the Transfer Pricing Rules?

Journal
International; OECD
Bulletin for International Taxation 2018 (Volume 72), No. 4a/Special Issue
In this article, the authors advance a possible solution to the challenges posed to international taxation by the digitalization of the worldwide economy. They argue that the proper application of the transfer pricing rules solves a problem of profits attribution to all the jurisdictions where digitalized companies generate their value.