Transfer Pricing Challenges in the Digital Economy: Hic Sunt Dracones?

14 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: Hic Sunt Dracones? (Part I of II),” published in Bloomberg’s Tax Management International Journal. The authors discuss the current OECD and IRS transfer pricing frameworks and whether they adequately reflect value creation in evolving digital business models. They conclude that, because we have little information available on how new business models will operate and how they will impact taxation, the OECD should move slowly in rewriting its tax rules to accommodate the digital economy.

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