Transfer Pricing Challenges in the Digital Economy: A Case Study of the Internet of Things

30 June 2019
Dr. Niraja Srinivasan

Director Dr. Niraja Srinivasan and Dr. Lorraine Eden, Professor Emerita of Management at Mays Business School and Research Professor of Law in the School of Law at Texas A&M University, coauthored the article “Transfer Pricing Challenges in the Digital Economy: A Case Study of the Internet of Things (Part II of II),” published in Bloomberg’s Tax Management International Journal. There, the authors continue their discussion on current OECD and IRS transfer pricing frameworks and whether they adequately reflect value creation in evolving digital business models. They examine a stylized case study from the Internet of Things, exposing key challenges of applying existing transfer pricing models to novel business structures and showing areas where more work is needed.  

The paper is frequently ranked in SSRN’s Top-10 most downloaded publications in 2019 and 2020.