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

Abstract

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.

Keywords: Digital Economy, Internationals Taxation, Transfer Pricing, Tax Treaties

JEL Classification: K33, K34