The notion of value creation is gaining traction. Even the OECD emphasized aligning profit taxation with economic activity and value creation in the BEPS Actions 8-10 Final Reports. Further, the modern innovative business models in this era of the digital/data economy are giving rise to highly integrated value chains. The question arises as to (i) how to accurately describe these value chains in a manner that makes the value creation and value-capturing of data and digital business transparent for tax purposes; and (ii) how to analyse modern businesses acting in their very own and unique data ecosystems. Therefore, this article discusses the value creation and value chain aspects of data-driven businesses. Considering the above, this article first discusses the background of value chain analysis and its commonly used methods for transfer pricing purposes. Second, it attempts to establish a link between the concept of value creation in the data economy and the evolving data-driven business models and examines possible value chain analyses that might be able to describe these models properly. As an interim conclusion, the authors express the need for an adjustment of the current value chain analysis for digital/data-driven businesses, as it fails to integrate the ways in which the digital data ecosystem works. Therefore, for business models that rely heavily on data and for transactions that are data-intense/data-driven, the authors propose a quantitative approach, whereby the residual profit is attributed not only to profit and investment centres, but also to data function. As it is crucial for such a value chain analysis to appropriately reflect value creation, the authors also propose a framework of digital documentation tools to understand the economic reasoning behind those businesses.
The views in all sections are personal views of the author.