Scientific Publications
Our work at Kolabri is grounded in solid and interdisciplinary research. In the following, we proudly share selected articles of our scientific work.
Taxing Collaborative Software Engineering
published at IEEE Software
The engineering of complex software systems is often the result of a highly collaborative effort. However, collaboration within a multinational enterprise has an overlooked legal implication when developers collaborate across national borders: It is taxable. In this article, we discuss the unsolved problem of taxing collaborative software engineering across borders.
The Microsoft Case: Lessons for Post-BEPS Software Development Cost Contribution Arrangements
published at Tax Notes International
In this article, the authors examine how the particulars of collaborative software development affect how to structure a software development cost contribution arrangement so that it complies with arm’s-length considerations.
Describing Globally Distributed Software Architectures for Tax Compliance
under review at Empirical Software Engineering Journal
Background: The company-internal reuse of software components owned by organizational units in different countries constitutes an implicit licensing across borders, which is taxable. This makes tax authorities a less known stakeholder in software architectures.
Objective: Therefore, we investigate how software companies can describe the implicit license structure of their globally distributed software architectures to tax authorities. Method: We develop a viewpoint that frames the concerns of tax authorities, use this viewpoint to construct a view of a large-scale microservice architecture of a multinational enterprise, and evaluate the resulting software architecture description with a panel of four tax experts.
Results: The panel found our proposed architectural viewpoint properly and sufficiently frames the concerns of taxation stakeholders. However, unclear jurisdictions of owners and potentially insufficient definitions of code ownership and software component introduce significant noise to the view that limits the usefulness and explanatory power of our software architecture description.
Conclusion: While our software architecture description provides a solid foundation, we believe it only represents the tip of the iceberg. Future research is necessary to pave the way for advancements in tax compliance within software engineering.
Sustaining Arm’s Length Cost Allocations for Highly Integrated Development Functions—An Explorative Case Study of Transfer Pricing for InnerSource Communities
published at MNE Tax
Most contemporary developments in transfer pricing relate to intangibles. Appropriately coping with increasingly highly integrated value chains constitutes another driving force. This article examines the application of the arm’s length principle in the context of a related-party transaction characterized by integrated collaboration among decentralized business units and the joint utilization and development of intangibles. While the underlying theoretical transfer pricing concepts will be touched upon, we aim to present a case-based application of the arm’s length principle. The pragmatic approach presented in this article aims to support practitioners navigating the tradeoff between finding arm’s length solutions for increasingly complex, digitized organizations and effectively utilizing available internal data for transfer pricing purposes.
Brochure
In our new brochure on data analytics for transfer pricing in software engineering, you learn more about the data-driven approach underlying our consulting services.
Presentation
In a concise presentation, we outline Kolabri’s approach to transfer pricing for software engineering.