Transfer Pricing And Economic Substance In Remote Work

The rapid spread of remote work has fundamentally transformed the operational and management structure of multinational corporations. What originally began as a situational response to emergency global disruptions has quickly become a permanent component of modern business models. Work is no longer confined to traditional headquarters or geographical boundaries, but key functions, including executive and strategic functions, can be performed from multiple locations around the world. This shift has imposed a new reality on international tax rules and frameworks Transfer pricing, which has historically been based on the premise that there is a clear link between the location of economic activity and the place where value is generated.