E-Commerce and Transfer Pricing - Some Selected Issues

Davide M. Parrilli


The aim of this article is to draft a concise and clear picture concerning the applicability of transfer pricing regime in a typical e-commerce scenario. Provided twolegal and business models (intra-company transaction between head office and branch, and inter-companies transaction between parent company and subsidiary,or between two subsidiaries of the same group), we will assess whether, and to what extent, a website and a server, used by the enterprise or the group to carry on its e-business, can be conceived as a permanent establishment and, then, we will analysewhich methods have to be used in order to apply the arm’s length principle. Our research will predominantly take into account the OECD Model Convention andTransfer Pricing Guidelines.

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