Transfer Pricing Implications in the Era of Crypto Assets

Within the framework of the Fourth Industrial Revolution, one of the most disruptive digital developments shaping the international landscape has been the emergence of crypto assets. These instruments are transforming how market participants conceptualize cross-border transactions and, fundamentally, the notion of digital value. In the context of international taxation, their implications for transfer pricing cannot be overlooked. In this article, the author explores how crypto assets intersect with current transfer pricing frameworks, identifies the legal challenges they present, and offers practical guidance for multinational enterprises navigating this evolving global environment.