Transfer Pricing

The Interplay between FAR Analysis and AOA in a Digitalized Economy

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

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.
With R. Iervolino and A. Orlandi


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