The Interplay between FAR Analysis and AOA in a Digitalized Economy

International Transfer Pricing Journal, 2021, Vol. 32, No. 1

Posted: 2 Mar 2021

See all articles by Amedeo Rizzo

Amedeo Rizzo

University of Oxford - Faculty of Law; Bocconi University

Alfredo Orlandi

affiliation not provided to SSRN

Raffaele Iervolino

affiliation not provided to SSRN

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

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

Amedeo Rizzo (Contact Author)

University of Oxford - Faculty of Law ( email )

St Cross Building
St Cross Rd
Oxford, OX1 3UL
United Kingdom

Bocconi University ( email )

Via Sarfatti, 25
Milan, MI 20136
Italy

HOME PAGE: http://didattica.unibocconi.eu/mypage/index.php?IdUte=210403&idr=&lingua=eng

Alfredo Orlandi

affiliation not provided to SSRN

Raffaele Iervolino

affiliation not provided to SSRN

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