Episode 64: Transfer pricing issues raised by the digitalization of the economy — A closer look at the OECD Pillar One Blueprint

November 24, 2020


This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options.


  • Kartikeya Singh – Principal, PwC US Washington National Tax Services
  • Giorgia Maffini – Senior Manager, Transfer Pricing and Tax Policy – PwC UK
  • Stefaan De Baets – Senior Manager, Transfer Pricing – PwC Belgium

Contacts: Kartikeya Singh, Giorgia Maffini, Stefaan De Baets

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Horacio Peña

Global Transfer Pricing Leader, PwC United States

Tel: +1 (917) 478-5817

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