TRANSFER PRICING IN THE DIGITAL ECONOMY: EMERGING CHALLENGES AND REGULATORY APPROACHES

Abstract

The rapid expansion of the digital economy has transformed international business models and created significant challenges for traditional transfer pricing frameworks. Digital multinational enterprises increasingly generate substantial economic value through intangible assets, digital platforms, data utilization, and cross-border online services, making it difficult for tax authorities to determine appropriate allocation of taxable profits among jurisdictions. As a result, transfer pricing has become one of the most debated issues in international taxation and corporate finance.