Transfer pricing: the american experience and the digital revolution

Abstract

The phenomenon of transfer pricing is becoming more widespread in the largest companies in different countries. However, for the first time it began to be implemented in American concerns at the beginning of the last century. The usual market mechanism was not suitable for intra-company management, which had to solve the tasks of ensuring the smooth functioning of huge corporate complexes, including many links. Nowadays, in the context of the globalization of the world economy, transnational companies have acquired great importance, within which goods and services move across the borders of all countries of the world. Therefore, transfer prices have acquired an international character and international control over their application was required to take into account the national interests of each state. In this regard, official UN and OECD documents have been issued, the tax and antimonopoly legislation of the EU and individual countries. The introduction of digital technologies has had a significant impact on the transfer pricing mechanism in the United States, in other countries and worldwide. The digital revolution has not changed the nature of transfer prices, but has expanded their functions and scope. These issues are the subject of this article