The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented public discussion regarding the taxation of digital business models highlight the importance and complexity of the arm's length principle. In a theoretical model of an internationally fragmented...

The “fair” taxation of digital business models is challenging. One of the key aspects — both policy makers and the public opinion consider as most pressuring — is the determination of intragroup transfer prices for intangibles used in digital business models. In this paper, we address...

The "fair" taxation of digital business models is challenging. One of the key aspects - both policy makers and the public opinion consider as most pressuring - is the determination of intragroup transfer prices for intangibles used in digital business models. In this paper, we address the issue...

On October 9 the OECD Secretariat published its “Proposal for a Unified Approach” (UA) which considered to deliver the answer to the tax challenges raised by the digitalization of the economy. This article starts with the problems (still) encountered after the OECD BEPS project and converts...

The international tax system faces substantial challenges with respect to taxing the profits of multinational companies in the digital economy. Both policymakers and taxpayers consider the determination of intra-company transfer prices the most pressing issue. This article analyses existing...