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Economic analysis to determine an appropriate split of a jointly generated profit is rooted in game theory. One of the most significant issues facing the transfer pricing community, and the wider business society, concerns the taxation of the digital economy. Generally, two challenges are raised regarding this issue: first, that digital companies supposedly pay low taxes due to the excessive use of loopholes and, second, more intricately, that the rise of the digital economy leads to a new dynamic between market states and the host countries of these companies. In particular, market jurisdictions claim that a high value is generated from the data provided by users in their countries and that this value is not captured fairly.

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