Cloud, SaaS, platforms, data IP, under the OECD framework and Pillar One/Two.

FAQ

Questions on tp and digital business transformation.

• Why don't SaaS and cloud business models fit traditional transfer pricing categories?

  A SaaS subscription blends elements of a service, a licence, and sometimes an intangible transfer in one contract, and the traditional service-vs-licence categorisation OECD guidance was built around doesn't map cleanly. The practice classifies by economic substance — what is actually being delivered — rather than the contract's label.

• What is Amount B, and does it apply to digital businesses?

  Amount B (Pillar One) is the OECD's simplified pricing framework for baseline marketing and distribution activities. Its list of covered jurisdictions is still expanding in 2026, and digital distributors increasingly fall within scope where they perform routine market-facing functions alongside their platform activity.

• How is data treated as an intangible asset for transfer pricing purposes?

  Data-as-IP analysis follows the same DEMPE framework applied to any intangible: which entity develops, enhances, maintains, protects, and exploits the dataset determines who earns the return, regardless of which entity's contract labels it as the data owner.