New Technologies and Transfer Pricing in the BRI Juristictions

This paper explores the linkage between emerging new technologies and transfer pricing, and the mechanisms available to minimise and resolve disputes in this area. It explores the way that these technologies can help achieve a better ap¬plication of the Arm’s Length Principle (ALP) which remains the bedrock for transfer pricing around the world. It also identifies the way that both MNEs and Tax Admin¬istrations can use these technologies to get access to more comparable information and to achieve greater consistency in the allocation on the basis of the ALP. Finally, some new ways of achieving more effective cross-border resolution mechanisms in the BRI jurisdictions are explored.
Keywords: Transfer pricing; Technology; Cross-border tax disputes; Tax certainty; BRI jurisdictions