Companies’ digital business models raise many questions about transfer pricing. Current rules may not be enough to address how a company’s transfer pricing should be handled when a company is primarily digital—when its primary business is collecting data from its customers, moves it around within the company, and funnels it back to customers in the form of information and insights; and when its employees can work from home or shift from one workplace to another.
Bloomberg Tax spoke with Niraja Srinivasan, a director at NERA Economic Consulting, about digital business models and transfer pricing, and how the reallocation of corporate ...