The Interplay between FAR Analysis and AOA in a Digitalized Economy
International Transfer Pricing Journal, 2021, Vol. 32, No. 1
Posted: 2 Mar 2021
Date Written: January 5, 2021
Abstract
The article examines the analysis of the significant functions of a permanent establishment in a digitalized economy as well as the attribution of assets, risks, capital and liabilities to the latter with specific considerations related to digital businesses. Specifically, the article analyses how the “Authorized OECD Approach” interlaces with the aspects of the digitalization of the economy, among which the “Unified Approach” under Pillar One.
Suggested Citation: Suggested Citation
Rizzo, Amedeo and Orlandi, Alfredo and Iervolino, Raffaele, The Interplay between FAR Analysis and AOA in a Digitalized Economy (January 5, 2021). International Transfer Pricing Journal, 2021, Vol. 32, No. 1, Available at SSRN: https://ssrn.com/abstract=3762441
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