U.S. Intercompany Pricing Rules Are Outdated: Dell Official

Multinational companies with a digital value chain face significant compliance challenges because of outdated U.S. transfer pricing rules, a tax official from Dell Technologies said.

Complying with the traditional transfer pricing section of the U.S. tax code is “force-fitting into an older model,” said Niraja Srinivasan, head of global transfer pricing for Dell Technologies. “I think there’s a limitation with the way 482 is laid out right now in addressing a correct characterization of entities that are participating in that digital value chain or network.”

For example, in a digital value chain, data may generate value, but it may be ...