Value creation in the beps era and a new approach to transfer pricing for intangibles

General principles of international tax law for the localization of cross-border income in the space. The localization of cross-border income according to the standard of “value creation” in a post-beps system. The application of “value creation” approach to transfer pricing. The digitalization of the economy and the “value creation” challenges. The rise of the digitalization of the economy and the international tax debate. Users and data as possible taxable connecting factors and the implications for the transfer pricing rules