Transfer Pricing in the Digital Age: Addressing Intangibles and Value Creation

Abstract

This paper explores the complexities and evolving practices of transfer pricing in the digital age, emphasizing the challenges associated with intangibles and value creation. With the rise of digital business models, traditional transfer pricing methods struggle to accurately capture the value of intangible assets such as intellectual property and data. This study examines the impact of digitalization on transfer pricing frameworks, evaluates current international guidelines and national policies, and offers recommendations for businesses and policymakers to navigate these challenges effectively. By analyzing case studies and recent regulatory developments, the paper aims to provide insights into developing robust transfer pricing strategies in the digital economy.