Статті в журналах з теми "Value creation. Transfer pricing. Intangibles"

The author discusses specific concerns about the efficacy of the application of transfer pricing rules to aspects of business models that have been addressed in the revisions to the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines contained in the 2015 base erosion and profit shifting (BEPS) Report, Aligning Transfer Pricing with Value Creation. Distinctions are made between business models and transfer pricing business models that risk constraining the business to convenient explanations. Transfer pricing business models involving transfer of contractual risk and of legal ownership of intangibles are examined. Finally, the author predicts interest in single entity cross-border business models and the need to develop consistent guidance on attribution of profits to permanent establishments.

Business models in a global context have evolved at a much speedier pace than the international tax framework. The internet of things, powerful corporate identities, innovative ways to play the market and an increasing reliance on intangibles are vital elements that lead to unprecedented ways of ‘value creation’. The Base Erosion & Profit Shifting (BEPS) project by the Organisation for Economic Co-operation and Development (OECD)/ Group of Twenty (G20) aims at ensuring that profits are effectively taxed where the economic activities generating the profits are performed. This is embedded in the premise that transfer pricing outcomes should be aligned with value creation. Many tax authorities and tax practitioners grapple with interpreting and translating value creation under innovative business models of multinational enterprises (MNEs) to the transfer pricing dictionary. In this article, the authors describe by means of examples how successful companies nowadays create value and unlock ‘economic rent’ across the value chain based on distinctive capabilities and unique business models. The authors subsequently put forward a novel economic approach to grasp value creation from a tax perspective in order to test whether there is a match with the transfer pricing outcomes. They started from the insights shared in ‘Strategy that works’ from PwC Strategy&, a playbook for the C-Suite to close the ‘strategy-to-execution’ gap.

Indonesia has recently updated its Advance Pricing Agreement and transfer pricing regulations in order to capture the development in the business and transfer pricing. It is also aimed to align with the Base Erosion and Profit Shifting (BEPS) recommendations. The new regulation has made substantial changes to the old advance pricing agreements (APAs) and transfer pricing regulations. With regards to transfer pricing, the new regulation has made some changes pursuant to the related parties’ definition, transfer pricing methods, comparability analysis procedures, special transactions, and intangibles. The transfer pricing guidance also provides guidance on the financial transactions and introduces the value creation concept. The new definition of related party is broader by providing more example on the ownership based on control. The regulation also allows the use of other transfer pricing methods other than the five OECD methods. Moreover, the intangible provisions have been modified to reflect the changes in the OECD Transfer Pricing Guideline 2017, to cover development, enhancement, maintenance, protection, and exploitation (DEMPE) activities and the economic owner. The guidance on financial transaction could also be useful for taxpayers and tax administration. Meanwhile, in terms of APA, the new regulation has provided a longer period of APA implementation, included a roll-back provision and modified the requirements regarding the submission of APA. Based on the new APA regulation, to submit an APA, a taxpayer cannot propose a lower profit than profit reported in the tax return. In general, the new regulation is in line with the BEPS 8-10 recommendations, albeit some differences are found, those are considered minor. The new regulations are expected to provide more certainty and simplicity for the taxpayers. Transfer pricing, APAs, Indonesia, advance pricing agreement, transfer pricing guidance, roll-back, related party, affiliated, transfer pricing methods, comparables

Value creation vis-à-vis the DEMPE rationale and methodology converted a conceptual notion associated with contributions to value creation but lacking prescription into a new standard to allocate profits to achieve reunification for tax purposes in a manner consistent with the directions of the arm’s length principle (ALP). Within this context, this article questions whether value creation could or should be based on a functional (i.e. DEMPE)-formula-based standard to allocate profits, and whether such an approach would target or abet tax avoidance framed by apparently genuine structures –‘accurately delineated’ (i.e. alignment of the allocation of profits with value-generating activities) that, in terms of how income is earned, might not be commercially rational. That said tax avoidance one that goes beyond the customary understanding and limitations of abuse under domestic law norms which paradoxically could make tax planning considered "abusive" easier to sustain within the BEPS precepts. Thus, the functional (i.e. DEMPE)-formula-based standard coupled with the commercial rationality test needs to be interpreted in a way that determines whether the performance of those functions by each party in a specific jurisdiction is rational from a commercial/business purpose perspective based on certain business parameters to provide taxpayers with a higher level of certainty, and in turn to devise suitable objective standards concerning the meaning of rationality in business operations for which typically there are open variuos legally sustainable ways to achieve the same economic outcomes. Value creation, intangibles, Actions 8–10, transfer pricing, source, commercial rationality, substance, anti-avoidance, arm´s length principle, fractional.

Background. The Organization for Economic Co-operation and Development has laun­ched a number of initiatives to solve global tax problem, since there are incon­sistencies and gaps in the international tax legislation. The BEPS Plan is the most signi­ficant of these initiatives. Analysis of recent researches and publications. The review of scientific articles and publications revealed the relevance of the study of the analysis of the conditions of opera­tions controllability with intangible assets and the choice of transfer pricing method through the identification of potential signs of comparability. The aim of the article is to study the approaches to the transfer pricing of intangible assets in the BEPS context in accordance with the concept of their implementation of the "outstretched hand" principle. Materials and methods. Different methods of scientific knowledge such as analysis, synthesis, deduction and induction, as well as methods of comparison, generalization and systematization have been used in the article. Results. Modern tendencies of development of the sphere of intellectual property have been analyzed. The globalization dimension of the processes of intellectual property formation has been studied and the place of Ukraine in these processes is revealed. The main trends of foreign economic transactions with intangible assets are identified. Business transactions with intangible assets for the purposes of transfer pricing are specified. The main measures for the implementation of the BEPS Action Plan in Ukraine are presented. Conclusion. It is identified that the results of comparability of the conditions of the controlled operation, the parties to the controlled operations with intangible assets should receive compensation based on the value they create through the performed functions, used assets and risks assumed in the development process, strengthening, maintenance, pro­tection and use of such assets. This necessitates the formation of approaches to the tax admi­nistration of transfer prices, which will ensure the creation of competitive economic relations, the introduction of clear and transparent mechanisms for determining contract prices. Keywords: transfer pricing, related parties, controlled transactions, BEPS, intangible assets, royalties, international trade in services.

Economic globalization and demographic changes as well rapidly changing technologies are the most important factors of the firm's environment. The rapid development of information technology radically changes the very essence of the creation of new value. The pace of technological change and innovations increases. In the most advanced sectors of global economy the knowledge is a key resource. The world economy has not finally recovered after the crisis of 2008-2009. The global economy his becoming more multicentre and the vector of economic power is shifting to China and India. The main actors and the anchor of today global economy are leading international companies (transnational corporations- TNCs). Several thousands of TNCs together with their value chain dominate the global economy. The economic power allows the largest TNCs significantly push the boundaries of the company. Globalization has changed external networks of TNCs, their corporate governance, corporate ownership as well transfer pricing schemes as well relations between the headquarter and its subsidiaries and affiliates. A remarkable feature of TNCs recent FDI flows is not Greenfield investment but mergers and acquisitions. Key features of TNC activities are defined by industry. A growing number of TNCs are changing their strategic activities, basing on the latest technology trends. The most important aspects of TNCs activities are linked to innovation, financial operations, advanced management technique, increase in intangible assets. Innovation activity of TNCs is shifting to Asia.

AbstractIn 2015, the OECD gave the world a template to address base erosion and profit shifting and ensure that profit is taxed in the jurisdiction of value addition and / or where economic activities take place. The world's jurisdictions then embarked on implementing the template. Examining the legal framework subsequently put in place for the taxation of intangibles in Nigeria, this article argues that the distinct regimes for connected and unconnected persons’ transactions create flaws. It further asserts that these flaws are consequences of the conflict between the policy that underpins the legal framework and other policies in the country. It concludes that the legal framework may not be a “Swiss army knife” (providing Nigeria with all that is needed to combat transfer pricing issues associated with the transfer of intangibles by connected persons), as it creates issues that have undesired consequences for the taxation as well as the economic system.

Purpose – The purpose of this paper is to integrate the issue of transfer pricing and logistics costs to understand trade statistics and the operation of supply chains by using invoice-level data for a single globally sourced product of a multinational firm.Supply chains are central to understanding wealth creation and capture in an increasingly globalized production system. The increasing disaggregation and dispersal of supply chains is profoundly affecting the geographical distribution of value added, input costs and profits of multinational firms. This suggests that understanding supply chains and where the activities and accounting for these activities take place is crucial for understanding the causes and consequences of contemporary globalization. Design/methodology/approach – By using a case study of a single product and invoice-level data, it was possible to capture the actual costs incurred by a firm using a relatively simple global supply chain. The authors show how corporate intra-firm transfer pricing determines which business unit and location captures profits. A single firm provided the core data in this paper, including product- and firm-level information on intermediate product prices and input costs for all internal transfers. Findings – This paper advances interesting insights into trade in value added and shows that, though not often considered significant, transfer pricing is a critical issue for understanding the geographical distribution of value added. The authors conclude with some observations about the nature of global supply chains, the value of international trade statistics and a hidden advantage of an integrated firm operating on a global scale the ability to somewhat arbitrarily select the activities to which profits should be allocated. For nation states, as supply chains become more international and complex, critical measures, such as gross domestic product, worker productivity, etc., are becoming ever more imprecise. The economic geography of cost of inputs and profits continue to separate as multinational enterprises drive the disaggregation of value creation and value capture. Research limitations/implications – The case study facilitates an understanding of complex supply chain issues, thereby extending and deepening findings from previous research. This case study of transfer pricing in supply chains will assist other scholars in better formulating testable propositions for their studies and sensitize them to the internal complexities corporate managers face when making operationalizing decisions. Originality/value – The case study suggests that understanding the configuration of and accounting in supply chains is vital for accurately measuring any national economic statistics. This case study provides some bottom-up evidence that national accounts and international trade economics undertaken without a deep understanding of supply chain organization is likely to generate misleading results. The methodology of using invoice-level data can provide a more granular understanding of how supply chains are organized and where the value is added and captured. For practitioners, the data suggest that firms should think very carefully about which of their activities generate the most value, and value those accordingly.

This paper deploys Transaction Cost Economics (TCE) to elaborate on the shortcomings of ‘mainstream‘ transfer pricing in multinational firms. Departing from the notion that multinationals increasingly (re-)organize their business along multinational value chains irrespective of jurisdictional borders, this paper discusses the nature of the multinational firm and the problem of choosing the right intra-group (transfer) price. The mainstream transfer pricing approach derived from the Arm�s Length Principle (ALP) is deemed inappropriate for globally operating multinational enterprises (MNEs). Referring to the value chain model, the paper suggests that ‘entrepreneurial coordination’ is the key performance feature to be used for valuing business activity and for allocating — for tax transfer pricing purposes — standard mark-ups and residual profits along the value chain. The main findings of this paper are: Neo-classical concepts on marginal pricing may not suffice to establish arm's lengh transfer pricing; the inadequacy between tax-world transfer pricing (getting income allocation right) and business-world transfer pricing (getting management incentives right) might find its explanation in such concepts. MNEs need to be understood as large organizations different from domestic large organizations by the fact that they operate in different jurisdictions and/or institutional environments. Operative business is coordinated along business lines in which value chain processes can e identified. De facto, business-world transfer pricing takes place along such value chains in which tangible and intangible assets are transferred and hence require appropriate pricing from both the tax-world and the business-world perspective. TCE is a worthy candidate for illustrating governance structures and transactional attributes of business between related parties of a multinational group; such features support arguments to establish arm's length transfer pricing. Regularly, a clear cut-off of functional allocation into tax jurisdictions is difficult to achieve because of the high degree of integration into the value chains of the multinational. TCE appears to better distinguish between so-called �routine� and ‘non-routine’ functions. Transactions of the MNE are rarely of an ‘either-or’ feature (either ‘market’ or ‘hierarchy’). Depending upon transactional attributes, the price of such transaction can be assessed by variables describing the institutional and economic context, the transaction-specific contract, the stage of the business process involved, the strategy chosen, and the function pattern (function, risk, assets) Comparable information is rarely found in databases which provide company information. The more non-routine functions and intangibles are involved, the less is the tested function (or business unit) comparable with companies from external databases. Under these data constraints on comparables, the arm�s length tests on transfer pricing will have to resort to internal information if the ALP is intended to remain viable. A next-generation transfer pricing approach may have to make use of patterns of governance to characterize and to value the functional contributions to the overall value chain.

The article is devoted to transfer pricing rules with particular reference to unresolved problems. Its purpose is to outline the complex issue of transfer pricing. The author examines the difference between the concepts of “market price” and price, determined according to the “arm’s length principle”, discusses the basic rules of taxation, principles of determining the price of goods, work or services for taxation purposes. To ensure the correct application of the separate entity approach, countries have adopted the arm´s length principle. This article analyzes initiatives on taxation in the area of corporate taxation (OECD Action Plan on Base Erosion and Profit Shifting (BEPS), Final Reports “Aligning Transfer Pricing Outcomes with Value Creation”). The author points out that the level of control (direct or indirect) in determining interdependence between persons, has its own specific features in different states. The reason behind it is that the problem of transfer pricing does not always arise, but only when subjects establish specific relations. The article characterizes the regulatory changes and developments in Russia.

This article contains an empirical analysis of the recent tax developments in five major tax planning hub jurisdictions (the Netherlands, Cyprus, Malta, Singapore, and Hong Kong) by testing their potential for attracting the important parts of the value chain (significant people functions, intellectual property (IP), and the digital infrastructure) in the context of the highly digitalized businesses (platforms, cloud computing, fintech, robotics, and artificial intelligence). The digitalized businesses require relatively less physical substance for the creation of significant economic value. The combination of tax incentives for Multinational Enterprises (MNEs) and start-ups, transfer pricing rules, rules for valuation of intellectual property (IP), and wage tax incentives are increasingly used by the ‘tax hub’ countries to win in the global economic battle for the most important parts of the digitalized value chains that exacerbate tax competition. Digitalization, tax policy, tax competition, tax hub, FDI, transfer pricing, Netherlands, Singapore, Hong Kong, Malta, Cyprus

About 70 % of today's world tradetakes place between related companies. Transactionsbetween them are called assignment or transfer, andthe prices at which the group of related companiesaccounted value of the purchase and sale of financialresults, are called transfer pricing. The main aim ofthis paper is to determine the impact that transferpricing has on the creation of international tax issues.Transfer prices between related parties maysubstantially differ from the prices created for thesame or similar transactions between unrelatedindividuals in a free market. Transfer prices are animportant tax issue which is characterized byincreasing complexity and level of commitment of taxauthorities around the world on this issue.

In anticipation of the release of the new Chapter IX of the Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines, this article looks at the potential impact that the outcome of the Base Erosion and Profit Shifting (BEPS) project will have on business restructurings. Specifically, the article examines some of the areas of convergence and divergence between the 2010 version of Chapter IX and the new guidance issued under the BEPS Actions 8–10 Final Reports (Aligning Transfer Pricing Outcomes with Value Creation). Whilst the new guidance arising from Actions 8–10 is anticipated to offer additional clarifications in the area of business restructurings, we note that there are additional areas of complexity which are likely to lead to increased controversy for multinational enterprises (MNEs), with double taxation as an inevitable result.

How do private equity firms decide on a fair price for a business? Drawing on 76 semi-structured interviews, this article contributes to the sociology of finance and valuation studies by showing that pricing companies is not just a valuation operation but also a capital-repartition issue. In so doing, it shows how concrete, local pricing methods contribute to the financialisation of the economy through the creation of a new capital accumulation centre. The article’s ethno-accounting approach describes three pricing steps: first, the capital access rules applicable to the private equity firm members (the price rationale); second, the expectations about the capital that can be transferred from the business to the private equity firm (the theoretical price level); and third, the transaction participant coordination mechanisms (culminating in the actual price). This description of the practices and concepts inherent in business valuation sidesteps the traditional divide between price formation in constructivist concepts of value as well as price discovery in substantivist concepts of value. Instead, value is defined as the expectation of a transfer of capital from the productive sphere to the private equity firm.

One of the factors in achieving national development goals of the Russian Federation is to address corporate-wide issues of the systemically important holding company OJSC “Russian Railways”. These issues include improving efficiency of resource consumption processes and managing the value chain. The purpose of the study is to develop methodological support for transfer pricing management and control of internal corporate settlements to address the specified issues. The methodological framework of the study is formed by management accounting concepts and legal support guidelines on strategic industry development of the Russian Federation. The study methodology based on the use of the methods of concept operationalization, structural analogy, induction, deduction, detailing, grouping ensures formation of the evidence base of obtained results of the study: the author-developed methodical support for transfer pricing management to justify the least expensive cost of the end-to-end technological process; classifier of additional accounts of the management accounting to prepare currently applicable internal regulations and organize the data. It is concluded that the obtained results of the study can serve as an effective tool for making strategic decisions to determine potential cost for the prospective value creation of systemically important transport companies.

This article deals with the theoretical problem of whether the arm’s length principle could be derived from EU law and whether such principle would offer a single answer to the allocation of synergy rents. The author puts forward two main arguments. First, he asserts that, under ECJ case law, unless a deviation from the general tax system set forth by domestic law of the Member State (reference system) is identified, transfer pricing cases will be generally an issue of tax disparity. Therefore, the alleged advantage would not attributable to the Member State. Second, the author holds that deriving an EU law arm’s length principle from Article 107(1) of the Treaty on the Functioning of the European Union means to build up a supranational reference system. Such reference system is not an obvious derivation from the equality principle, but a matter of allocation of taxing rights among jurisdictions, with significant and contingent tax policy impacts. If the ECJ chooses to follow this path, it will tie future direct tax decisions to the manifold consequences of the policy elected – which currently seems to be the OECD/G20 BEPS Project ‘value creation’ trend. Both arguments are illustrated through an analysis of the Belgian excess profit regime. The article is not a defence of the Belgian system, but merely uses it as an example, stressing the inconsistencies that arise from the supranational reference system argument.

A comparability analysis forms the core of transfer pricing and involves the analysis of controlled transactions and the search for the right comparable. However, difficulties often arise in exactly matching the identified comparable to the controlled transaction. Hence, various comparability adjustments (such as the accounting, balance sheet, etc.) are undertaken primarily to eliminate differences and to achieve greater comparability between the comparable transactions/companies selected and the controlled transactions/companies under analysis. It is pertinent to mention that many of the commonly used adjustments cannot entirely take care of all of the functional and economic variations pre-existing between the comparable and the controlled transactions (one such problem area is the functional variation that occurs due to rapid digital and technological advancements and changes). The authors, therefore, believe there is a need to devise and implement a change (i.e., digital data intensity adjustment that could account for the differences between comparable companies due to these digital/data developments. In the context of the above background, the paper summarizes some of the existing comparability adjustments; thereafter, it highlights the need for a new adjustment to keep pace with the growth of the digital/data economy along with a case study. Further, certain broad frameworks for this new adjustment are discussed. Digital services tax, digital economy, value creation, user data, social media, online advertising, sharing economy

Purpose The purpose of this paper is to investigate the impact of factor-based trading strategies on pricing and volume. Design/methodology/approach The authors employ a regression discontinuity approach to identify abnormalities in volume or pricing around expected portfolio changes. In addition, the authors characterize more granular effects on pricing and volume as a result of portfolio re-classification through Fama and Macbeth (1973) regressions. Findings The authors find that firms which are predicted to transfer among the factor portfolios of Fama and French (1993) exhibit strong and statistically significant short-term variation in stock price and volume. Short-term returns around the cutoff values comprising SMB and HML tend to be temporarily high if the firm is predicted to move into a long component of a factor-mimicking portfolio, and temporarily low if moving into a short component. Similar results are apparent when examining movement in and out of the 25 size and book-to-market sorted test asset portfolios. Practical implications The use of portfolio strategies formulated on the basis of sorting procedures, while once upon a time a niche market in the portfolio management industry, is now ubiquitous. The results of this study raise interesting methodological questions about the pricing implications arising from these common methodologies. Originality/value This study makes a number of contributions. First, it contributes to the idea that the publication or dissemination of trading strategies or – more generally – common portfolio sorting methods, leads to effects on pricing and volume through commonly motivated trading pressure. In other words, recipe-like discoveries of advantageous trading strategies lead to a synthetic creation of demand. Second, by noting that a lot of factor-focused trading activity begins around July and August of each year, the study relates to existing literature which documents seasonal variation in stock returns and volume. The findings raise questions about what guides institutional investors’ portfolio allocation decisions and whether these are optimal in aggregate.

Quantifying and designing the cost pool generated by Business Intelligence and Analytics (BI&A) would improve cost transparency and invoicing processes, allowing a fairer, more exact allocation of costs to service consumers. Yet there is still no method for determining BI&A costs to provide a base for allocation purposes. While literature describes several methods for BI&A cost estimation on an ROI or resource-consumption level, none of these methods considers an overall approach for BI&A. To tackle this problem, the authors propose a service- oriented cost allocation model which calculates BI&A applications based on defined services, enabling a cost transfer to service consumers. This new approach specifies steps towards deriving a usable pricing scheme for an entire BI&A service portfolio – both for allocation purposes as well as improving cost evaluation of BI&A projects. Moreover, it increases customer understanding and cost awareness. Based on this approach, the authors introduce a BI&A value creation cycle which helps customers to use BI&A services cost-effectively.

The creation of regional centers of standardization in the field of distribution and use of energy flows of an alternative type contributes to the consistency of the quality of energy supply and logistics services of high-tech enterprises (HTP) and housing and communal services (housing). The integrated combination of the latest forms of marketing communications and logistics service is based on the interaction and interpenetration of important types of marketing activities of industrial enterprises during the movement of resource flows in global and regional value chains focused on sustainable development. Logistics service contributes to a fuller adaptation of the vector of goods supply of enterprises to the demands of potential segments of the target market. Innovative and technological development encourages the constant improvement of means and methods of communication support of logistics services. The implementation of a set of business opportunities aimed at creating joint high-tech projects in the areas of technology transfer and commercialization of innovations is possible through the comprehensive integration of education, science and business. Theoretical and methodological components of marketing strategic planning, pricing, organization of marketing of energy saving events at high-tech enterprises were investigated. It is determined that the budgeting of marketing communications, taking into account the integrated application of unconventional marketing communications tools, pricing methods that focus on demand and competition, contributes to good training and clarification to social and economic agents, authorities, and the public. The feasibility of using innovative energy-saving technologies based on alternative energy sources is explained. It has been established that marketing energy-saving values of high-tech enterprises lie in the formation of marketing values for consumers, which creates competitive advantages in faster and more complete satisfaction of consumer needs. The concept of “marketing value” is developed, which reflects the impact of relational tools of cholistic marketing on communication support and logistical support for interaction with economic agents, stakeholders, consumers, which leads to the intensive formation of marketing values among noted interaction entities. Marketing communication motivational and behavioral components of high-tech enterprises are highlighted. The marketing activity of “BIZON-TEH 2006” enterprise was analyzed, which has many years of experience in the agricultural market of Ukraine, is included in the TOP-3 of the largest distribution of seeds and fertilizers.

Purpose The purpose of this paper is to discuss tax and accounting issues related to the evolution of the intellectual property box in Portugal and present a preliminary view of its impact. In 2014, Portugal adopted an Intellectual Property (IP) box, exempting from corporate taxation half of the gross revenue obtained from selling IP rights. In 2016, the country adopted a new IP regime, in line with BEPS’ recommendations, with stricter rules for exempting income. The “modified nexus approach”, recommended by the OECD, was the cornerstone of legal changes. The research questions addressed in this paper are as follows: was the Portuguese IP box, set up in 2014, internationally competitive in terms of the scope of qualifying assets and the tax rate when compared to other EU countries? Could its legal design induce potential corporate tax avoidance? Does the new IP box framework reduce avoidance opportunities and does it increase tax and accounting complexity for companies and tax auditors? Design/methodology/approach The methodology used in this paper is based on the legal research method combined with a case study analysis of the IP box in Portugal. The economic motivation for legal changes, the interaction between the tax authorities and the policy makers in the wake of BEPS’ recommendations, and the economic crisis that Portugal faced, influenced legislative options. A multidisciplinary approach is required to analyse the IP box modifications, and the methodology follows this line of enquiry. Findings The author concludes that the 2014 IP box was not competitive in terms of the scope of qualifying assets and the tax rate. However, it could be a potential tool for tax avoidance, mainly linked to transfer pricing strategies. Legal changes, introduced in 2016, by enacting stricter rules for granting tax benefits, fit a worldwide trend of restraining profit shifting opportunities linked to intangibles. The new framework clearly impacts tax and accounting complexity, for companies and tax auditors. Preliminary data, for 2014 and 2015, show a negligible impact of the IP box on corporate taxation. Practical implications The “modified nexus approach” is not a definitive panacea for fighting tax avoidance. Multinationals may move resources (e.g. highly specialized persons) to entities that are developing IP, curtailing the restriction associated with acquiring services from related parties. Tax authorities may fight these schemes, but face a challenging task. The grandfathering option and new accounting choices related to expense allocation are delicate issues. Not all countries adopted BEPS’ recommendations at the same time, which may impact international profit shifting activities and increase tax authorities’ costs to control them. The paper also provides preliminary and exploratory evidence that IP boxes, per se, do not suddenly raise the R&D activity of firms. Originality/value The analysis highlights legal, accounting and economic issues in dealing with changes in investment incentives and can or may be a useful remainder for countries in the process of setting up, or amending, IP boxes.

Purpose The purpose of this paper is to analyze within the knowledge management (KM) stream the relationship between KM and intellectual capital (IC) and entrepreneurship (E). IC is a pivotal intangible resource to firms to generate knowledge. Knowledge and information are strategic for today’s company life. IC is generated and dynamically recombined by knowledge, produces knowledge and is feed by knowledge itself, both codified and tacit. For those reasons, the paper is motivated to understand how IC can represent valuable knowledge and how it can turn into innovation, through KM and practices. It is also voted to stimulate literature on understanding how innovation can serve E capabilities for firms’ business models, as innovation is not necessarily linked to a technological breakthrough. IC is functional to KM practices, as entrepreneurs can use IC and knowledge as a strategic management toolbox to innovate. Design/methodology/approach The main aim of the paper is to understand the state of the art on these central issues in KM literature. The paper uses a structure literature review (SLR) methodology, gathering papers by Scopus database for the period 2000–2019, on the relationship between KM and IC and E. The second aim is to understand for future research how do managers use IC as an opportunity to innovate and as a vehicle to transfer knowledge. The authors wondered about the qualification/quantification of “knowledge” as a crucial component of IC, which is in turn the riskier, but the more representative, a component of intangibles assets in the era of knowledge. Findings As for the first research question, the findings show that, actually, as the research has been started, IC, KM and E are still engaged separately by scholars, even if few efforts to match them together have been performed. The results depict a general fragmented and unsystematic vision of the relationship between the three topics. As for the future of the research about these topics, the authors found that scholars should catch the opportunity to go beyond the traditional theoretical mainstream on these issues. There is an urge to move the focus of KM and IC research toward new models of their interconnection, by including the social capital, namely, knowledge capabilities (explicit or not), etc., which are able to turn knowledge in innovation and competitive advantage, from an accounting perspective (recognizing IC’s components affecting the performance of firms, among which knowledge is the most important) and from a theoretical point of view (reducing the misalignment between the epistemological concept of KM requirements and the effective perception of organizational KM activities to extract value from KM initiatives). Research limitations/implications The results, even if suffering from some limitations due to the performing of the methodology, offers several implications for academic research. The future of KM of the IC resources is clearly likely to lie on the recognition of the component of knowledge, as well as on the recognizing of new forms of social capital such as entrepreneurial capital, which is connected to innovation and creativity and firm value. An integrative framework of IC measurement should be built to link IC with KM and E. This is to guarantee that the measurement of IC does contribute to the efficiency and effectiveness of KM. Practical implications Practical contribution to accounting perspective. In fact, the relations between these three topics could be highly beneficial to validate, in the dynamic societies and organizations, how it is important the entrepreneur’s learning process and its content is fundamental in the quest for new business opportunities/innovations, stated that learning is a crucial factor for entrepreneurial activity and has a structural impact on business models of industrial organizations. The difficulty to recognize in the balance sheet human capital relation could be limited by the introduction of the component of KM practices codification and E attitude and influence to operate this transformation of human capital in organized structural capital. The authors would not give the solution to that problem. The authors just want to address the discussion. Social implications The inspiring conclusion from previous studies is to think in a new way at the role of knowledge-based IC in organizational E. Starting from the assertion that knowledge-based process of innovation and E are linked, it can be tested, also from case studies help or empirical application that organizations with a pleasant level of IC are more likely to be more innovative and in conclusion, have a higher market value. Originality/value The main contribution of this paper is to afford for the first time, to the best knowledge, an SLR on the interaction in literature among KM, IC and E, simultaneously, to understand where literature research actually is focusing and to lead future thoughts, at a managerial level, toward the interacting implications of KM and IC on value creation by innovation, which is one stream E literature. Although recently scholars have been concerning more empirically about the relationship between KM, IC and E, they are more focused on theoretical aspects than about new ways to look at IC. The future of KM and IC research is clearly likely to lie on the recognition of the component of knowledge, as well as recognizing new forms of social capital such as entrepreneurial capital, which is connected to innovation and creativity. An integrative framework of IC measurement through KM should be built to link IC measurement with KM. This is to guarantee that measurement of IC does contribute to the efficiency and effectiveness of KM practices.

Tax competitive policies can be effective in cases of a collaborated cross-border effort with international consensus on minimum thresholds and mechanisms for cross-country cooperation. However, aggressive uncoordinated tax competitiveness destroys value and shrinks the growth and prosperity of the industry. Hence, there is a need for tax certainty and common standards in international transfer pricing. The OECD has provided a framework for countries to move towards universal tax regimes that have common tax policies and coordinated implementation systems. This paper highlights the issue of AMP (advertising, marketing and promotion) costs in transfer pricing and seeks to establish the need for coordination among national tax systems. Ensuring consistency among the tax policies of the world’s nations is important for preventing instances of BEPS (base erosion and profit shifting) that are the products of the gaps between elaborately drafted and extremely complicated tax legislations. Creation of universal tax principles and their effective implementation is the only solution to this problem.

The article considers the change of vectors of strategic development of TNCs under the influence of global transformation of the external environment due to technological innovations, economic globalization and demographic. A multipolar world has emerged, in which the vector of economic development is moving to Asia, where the main forces are China and India. It is substantiated that the rapid development of information technology radically changes the very essence of creating new values: the pace of technological change and mass introduction of innovations is growing, in high-tech industries knowledge is becoming a key resource. Globalization has changed the approaches of TNCs to the ratio of corporate development strategy and development strategies of certain business units. The activities of TNCs today are not characterized by the creation of new foreign industries, and the acquisition of existing promising firms. Economic power allows the largest modern TNCs to significantly push the boundaries of the company. It is determined that the characteristic features of modern TNCs are that they are diversified broadly diversified holding structures with huge economic capacity, which, along with the parent company includes numerous foreign branches and subsidiaries, occupying a dominant position in the process of creation. additional value and division of labor, which leads to obtaining and maintaining through transfer pricing and other special mechanisms of monopoly profits, which are characterized by the existence of a single title of global property, reflecting the formation of international (transnational) financial elite. At the same time, many features of global TNCs are determined by industry characteristics. It is concluded that TNCs are moving to a strategic transformation of their activities taking into account the needs of the information economy. The most important aspects of the activities of leading TNCs are related to innovation, financial operations, advanced management techniques, growth of intangible assets.

The Kenyan government’s announcement of a new 10 percent tax in March 2013 threatened the future prospects of M-Pesa, Safaricom’s mobile money transfer service, which had revolutionized the way money moved in Kenya. The new tax would be levied on all cash transfers but was largely targeted at M-Pesa, which controlled around 80 percent of the cash transfer market. In response to the new tax, Safaricom, the mobile communications market leader, announced a 10 percent price increase.The case presents the structure Safaricom established in order to develop a mobile money transfer service in Kenya. As a concept, M-Pesa was unprecedented in Kenya: prospective customers had to get comfortable with the idea that a mobile communications company could provide a payment system, that transactions could be initiated through a mobile phone, and that nonbank outlets could provide cash-in/cash-out services. Even when the concept was accepted, however, customers needed a convenient network of agents to handle transactions, and stores needed to see demand from customers in order to be motivated to become agent outlets. Thus, in order to grow, M-Pesa needed to aggressively pursue and acquire both customers and agents in this two-sided market. Understand the complexity of pricing in two-sided markets Evaluate the profitability of different pricing strategies in two-sided markets Understand the effect of an innovation on the creation and capture of value Identify possible threats to competitive advantage in two-sided markets as well as in developing countries Understand the value of co-opetition and how cooperation with competitors and complementors can increase a company’s profitability

AbstractAs a response to widely reported corporate tax avoidance, the OECD/G20 Base Erosion and Profit Shifting process has relied on modifying the Transfer Pricing Guidelines in order to align taxation with economic substance, a form of incremental rather than radical change. We interpret this strategy of the OECD as an attempt to prevent a loss of authority without a politically risky complete overhaul. However, given the imperfect reconciliation – or even incompatibility – with persisting principles of international tax law, the incremental changes add to the complexity and incoherence of the guidelines on transfer pricing, leading us to expect an increase in conflicting assessments and uncertainty in the near future. Identifying a diminishing capacity of expert networks to achieve consensus on matters with strong distributional consequences, we argue that the incoherence of the system contains the seeds of its own transformation. However, due to vested interests in the current system and the reinforced capacity of the OECD to intervene in public discourses, we expect this transformation to be procedural and marked by conflicts over the meaning of the current guidelines, notably with regards to the arm’s length principle and the measurement of value creation.

Introduction In a 2019 report for the International Journal of Communication, Baym et al. positioned distributed blockchain ledger technology, and what would subsequently be referred to as Web3, as a convening technology. Riffing off Barnett, a convening technology “initiates and serves as the focus of a conversation that can address issues far beyond what it may ultimately be able to address itself” (403). The case studies for the Baym et al. research—early, aspirant projects applying the blockchain concept to music publishing and distribution—are described in the piece as speculations or provocations concerning music’s commercial and social future. What is convened in this era (pre-2017 blockchain music discourse and practice) is the potential for change: a type of widespread, broadly discussed, reimagination of the 21st-century music industries, productive precisely because near-future applications suggest the realisation of what Baym et al. call dreams. In this article, we aim to examine the Web3 music field as it lies some years later. Taking the latter half of 2021 as our subject, we present a survey of where music then resided within Web3, focussing on how the dreams of Baym et al. have morphed and evolved, and materialised and declined, in the intervening years. By investigating the discourse and functionality of 2021’s current crop of music NFTs—just one thread of music Web3’s far-reaching aspiration, but a potent and accessible manifestation nonetheless—we can make a detailed analysis of concept-led application. Volatility remains throughout the broader sector, and all of the projects listed here could be read as conditionally short-term and untested, but what they represent is a series of clearly evolved case studies of the dream, rich precisely because of what is assumed and disregarded. WTF Is an NFT? Non-fungible tokens inscribe indelible, unique ledger entries on a blockchain, detailing ownership of, or rights associated with, assets that exist off-chain. Many NFTs take the form of an ERC-721 smart-contract that functions as an indivisible token on the Ethereum blockchain. Although all ERC-721 tokens are NFTs, the inverse is not true. Similar standards exist on other blockchains, and bridges allow these tokens to be created on alternative networks such as Polygon, Solana, WAX, Cardano and Tezos. The creation (minting) and transfer of ownership on the Ethereum network—by far the dominant chain—comes with a significant and volatile transaction cost, by way of gas fees. Thus, even a “free” transaction on the main NFT network requires a currency and time investment that far outweighs the everyday routines of fiat exchange. On a technical level, the original proposal for the ERC-721 standard refers to NFTs as deeds intended to represent ownership of digital and physical assets like houses, virtual collectibles, and negative value assets such as loans (Entriken et al.). The details of these assets can be encoded as metadata, such as the name and description of the asset including a URI that typically points to either a file somewhere on the Internet or a file hosted via IPFS, a decentralised peer-to-peer hosting network. As noted in the standard, while the data inscribed on-chain are immutable, the asset being referred to is not. Similarly, while each NFT is unique, multiple NFTs could, in theory, point to a single asset. In this respect ERC-721 tokens are different from cryptocurrencies and other tokens like stable-coins in that their value is often contingent on their accurate and ongoing association with assets outside of the blockchain on which they are traded. Further complicating matters, it is often unclear if and how NFTs confer ownership of digital assets with respect to legislative or common law. NFTs rarely include any information relating to licencing or rights transfer, and high-profile NFTs such as Bored Ape Yacht Club appear to be governed by licencing terms held off-chain (Bored Ape Yacht Club). Finally, while it is possible to inscribe any kind of data, including audio, into an NFT, the ERC-721 standard and the underpinning blockchains were not designed to host multimedia content. At the time of writing, storing even a low-bandwidth stereo audio file on the ethereum network appears cost-prohibitive. This presents a challenge for how music NFTs distinguish themselves in a marketplace dominated by visual works. The following sections of this article are divided into what we consider to be the general use cases for NFTs within music in 2021. We’ve designated three overlapping cases: audience investment, music ownership, and audience and business services. Audience Investment Significant discourse around NFTs focusses on digital collectibles and artwork that are conceptually, but not functionally, unique. Huge amounts of money have changed hands for specific—often celebrity brand-led—creations, resulting in media cycles of hype and derision. The high value of these NFTs has been variously ascribed to their high novelty value, scarcity, the adoption of NFTs as speculative assets by investors, and the lack of regulatory oversight allowing for price inflation via practices such as wash-trading (Madeline; Das et al.; Cong et al.; Le Pennec, Fielder, and Ante; Fazil, Owfi, and Taesiri). We see here the initial traditional split of discourse around cultural activity within a new medium: dual narratives of utopianism and dystopianism. Regardless of the discursive frame, activity has grown steadily since stories reporting the failure of Blockchain to deliver on its hype began appearing in 2017 (Ellul). Early coverage around blockchain, music, and NFTs echoes this capacity to leverage artificial scarcity via the creation of unique digital assets (cf Heap; Tomaino). As NFTs have developed, this discourse has become more nuanced, arguing that creators are now able to exploit both ownership and abundance. However, for the most part, music NFTs have essentially adopted the form of digital artworks and collectibles in editions ranging from 1:1 or 1:1000+. Grimes’s February 2021 Mars NFT pointed to a 32-second rotating animation of a sword-wielding cherubim above the planet Mars, accompanied by a musical cue (Grimes). Mars sold 388 NFTs for a reported fixed price of $7.5k each, grossing $2,910,000 at time of minting. By contrast, electronic artists Steve Aoki and Don Diablo have both released 1:1 NFT editions that have been auctioned via Sotheby’s, Superrare, and Nifty Gateway. Interestingly, these works have been bundled with physical goods; Diablo’s Destination Hexagonia, which sold for 600 Eth or approximately US$1.2 million at the time of sale, proffered ownership of a bespoke one-hour film hosted online, along with “a unique hand-crafted box, which includes a hard drive that contains the only copy of the high-quality file of the film” (Diablo). Aoki’s Hairy was much less elaborate but still promised to provide the winner of the $888,888 auction with a copy of the 35-second video of a fur-covered face shaking in time to downbeat electronica as an Infinite Objects video print (Aoki). In the first half of 2021, similar projects from high-profile artists including Deadmau5, The Weekend, Snoop Dogg, Eminem, Blondie, and 3Lau have generated an extraordinary amount of money leading to a significant, and understandable, appetite from musicians wanting to engage in this marketplace. Many of these artists and the platforms that have enabled their sales have lauded the potential for NFTs to address an alleged poor remuneration of artists from streaming and/or bypassing “industry middlemen” (cf. Sounds.xyz); the millions of dollars generated by sales of these NFTs presents a compelling case for exploring these new markets irrespective of risk and volatility. However, other artists have expressed reservations and/or received pushback on entry into the NFT marketplace due to concerns over the environmental impact of NFTs; volatility; and a perception of NFT markets as Ponzi schemes (Poleg), insecure (Goodin), exploitative (Purtill), or scammy (Dash). As of late 2021, increased reportage began to highlight unauthorised or fraudulent NFT minting (cf. TFL; Stephen), including in music (Newstead). However, the number of contested NFTs remains marginal in comparison to the volume of exchange that occurs in the space daily. OpenSea alone oversaw over US$2.5 billion worth of transactions per month. For the most part, online NFT marketplaces like OpenSea and Solanart oversee the exchange of products on terms not dissimilar to other large online retailers; the space is still resolutely emergent and there is much debate about what products, including recently delisted pro-Nazi and Alt-Right-related NFTs, are socially and commercially acceptable (cf. Pearson; Redman). Further, there are signs this trend may impact on both the willingness and capacity of rightsholders to engage with NFTs, particularly where official offerings are competing with extant fraudulent or illegitimate ones. Despite this, at the time of writing the NFT market as a whole does not appear prone to this type of obstruction. What remains complicated is the contested relationship between NFTs, copyrights, and ownership of the assets they represent. This is further complicated by tension between the claims of blockchain’s independence from existing regulatory structures, and the actual legal recourse available to music rights holders. Music Rights and Ownership Baym et al. note that addressing the problems of rights management and metadata is one of the important discussions around music convened by early blockchain projects. While they posit that “our point is not whether blockchain can or can’t fix the problems the music industries face” (403), for some professionals, the blockchain’s promise of eliminating the need for trust seemed to provide an ideal solution to a widely acknowledged business-to-business problem: one of poor metadata leading to unclaimed royalties accumulating in “black boxes”, particularly in the case of misattributed mechanical royalties in the USA (Rethink Music Initiative). As outlined in their influential institutional research paper (partnered with music rights disruptor Kobalt), the Rethink Music Initiative implied that incumbent intermediaries were benefiting from this opacity, incentivising them to avoid transparency and a centralised rights management database. This frame provides a key example of one politicised version of “fairness”, directly challenging the interest of entrenched powers and status quo systems. Also present in the space is a more pragmatic approach which sees problems of metadata and rights flows as the result of human error which can be remedied with the proper technological intervention. O’Dair and Beaven argue that blockchain presents an opportunity to eliminate the need for trust which has hampered efforts to create a global standard database of rights ownership, while music business researcher Opal Gough offers a more sober overview of how decentralised ledgers can streamline processes, remove inefficiencies, and improve cash flow, without relying on the moral angle of powerful incumbents holding on to control accounts and hindering progress. In the intervening two years, this discourse has shifted from transparency (cf. Taghdiri) to a practical narrative of reducing system friction and solving problems on the one hand—embodied by Paperchain, see Carnevali —and ethical claims reliant on the concept of fairness on the other—exemplified by Resonate—but with, so far, limited widespread impact. The notion that the need for b2b collaboration on royalty flows can be successfully bypassed through a “trustless” blockchain is currently being tested. While these earlier projects were attempts to either circumvent or fix problems facing the traditional rights holders, with the advent of the NFT in particular, novel ownership structures have reconfigured the concept of a rights holder. NFTs promise fans an opportunity to not just own a personal copy of a recording or even a digitally unique version, but to share in the ownership of the actual property rights, a role previously reserved for record labels and music publishers. New NFT models have only recently launched which offer fans a share of IP revenue. “Collectors can buy royalty ownership in songs directly from their favorite artists in the form of tokens” through the service Royal. Services such as Royal and Vezt represent potentially massive cultural shifts in the traditional separation between consumers and investors; they also present possible new headaches and adventures for accountants and legal teams. The issues noted by Baym et al. are still present, and the range of new entrants into this space risks the proliferation, rather than consolidation, of metadata standards and a need to put money into multiple blockchain ecosystems. As noted in RMIT’s blockchain report, missing royalty payments … would suggest the answer to “does it need a blockchain?” is yes (although further research is needed). However, it is not clear that the blockchain economy will progress beyond the margins through natural market forces. Some level of industry coordination may still be required. (18) Beyond the initial questions of whether system friction can be eased and standards generated without industry cooperation lie deeper philosophical issues of what will happen when fans are directly incentivised to promote recordings and artist brands as financial investors. With regard to royalty distribution, the exact role that NFTs would play in the ownership and exploitation of song IP remains conceptual rather than concrete. Even the emergent use cases are suggestive and experimental, often leaning heavily on off-chain terms, goodwill and the unknown role of existing legal infrastructure. Audience and Business Services Aside from the more high-profile NFT cases which focus on the digital object as an artwork providing a source of value, other systemic uses of NFTs are emerging. Both audience and business services are—to varying degrees—explorations of the utility of NFTs as a community token: i.e. digital commodities that have a market value, but also unlock ancillary community interaction. The music industries have a longstanding relationship with the sale of exclusivity and access tailored to experiential products. Historically, one of music’s most profitable commodities—the concert ticket—contains very little intrinsic value, but unlocks a hugely desirable extrinsic experience. As such, NFTs have already found adoption as tools of music exclusivity; as gateways into fan experiences, digital communities, live events ticketing and closed distribution. One case study incorporating almost all of these threads is the Deathbats club by American heavy metal band Avenged Sevenfold. Conceived of as the “ultimate fan club”, Deathbats is, according to the band’s singer M. Shadows, “every single thing that [fans] want from us, which is our time, our energy” (Chan). At the time of writing, the Deathbats NFT had experienced expected volatility, but maintained a 30-day average sale price well above launch price. A second affordance provided by music NFTs’ ability to tokenise community is the application of this to music businesses in the form of music DAOs: decentralised autonomous organisations. DAOs and NFTs have so far intersected in a number of ways. DAOs function as digital entities that are owned by their members. They utilise smart contracts to record protocols, votes, and transactions on the blockchain. Bitcoin and Ethereum are often considered the first DAOs of note, serving as board-less venture capital funds, also known as treasuries, that cannot be accessed without the consensus of their members. More recently, DAOs have been co-opted by online communities of shared interests, who work towards an agreed goal, and operate without the need for leadership. Often, access to DAO membership is tokenised, and the more tokens a member has, the more voting rights they possess. All proposals must pass before members, and have been voted for by the majority in order to be enacted, though voting systems differ between DAOs. Proposals must also comply with the DAO’s regulations and protocols. DAOs typically gather in online spaces such as Discord and Zoom, and utilise messaging services such as Telegram. Decentralised apps (dapps) have been developed to facilitate DAO activities such as voting systems and treasury management. Collective ownership of digital assets (in the form of NFTs) has become commonplace within DAOs. Flamingo DAO and PleasrDAO are two well-established and influential examples. The “crypto-backed social club” Friends with Benefits (membership costs between $5,000 and $10,000) serves as a “music discovery platform, an online publication, a startup incubator and a kind of Bloomberg terminal for crypto investors” (Gottsegen), and is now hosting its own curated NFT art platform with work by the likes of Pussy Riot. Musical and cross-disciplinary artists and communities are also exploring the potential of DAOs to empower, activate, and incentivise their communities as an extension of, or in addition to, their adoption and exploration of NFTs. In collaboration with Never Before Heard Sounds, electronic artist and musical pioneer Holly Herndon is exploring ideological questions raised by the growing intelligence of AI to create digital likeness and cloning through voice models. Holly+ is a custom voice instrument that allows users to process pre-existing polyphonic audio through a deep neural network trained by recordings of Holly Herndon’s voice. The output is audio-processed through Holly Herndon’s distinct vocal sound. Users can submit their resulting audio to the Holly+ DAO, to whom she has distributed ownership of her digital likeness. DAO token-holders steward which audio is minted and certified as an NFT, ensuring quality control and only good use of her digital likeness. DAO token-holders are entitled to a percentage of profit from resales in perpetuity, thereby incentivising informed and active stewardship of her digital likeness (Herndon). Another example is LA-based label Leaving Records, which has created GENRE DAO to explore and experiment with new levels of ownership and empowerment for their pre-existing community of artists, friends, and supporters. They have created a community token—$GENRE—for which they intend a number of uses, such as “a symbol of equitable growth, a badge of solidarity, a governance token, currency to buy NFTs, or as a utility to unlock token-gated communities” (Leaving Records). Taken as a whole, the spectrum of affordances and use cases presented by music NFTs can be viewed as a build-up of interest and capital around the technology. Conclusion The last half of 2021 was a moment of intense experimentation in the realms of music business administration and cultural expression, and at the time of writing, each week seemed to bring a new high-profile music Web3 project and/or disaster. Narratives of emancipation and domination under capitalism continue to drive our discussions around music and technology, and the direct link to debates on ecology and financialisation make these conversations particularly polarising. High-profile cases of music projects that overstep norms of existing IP rights, such as Hitpiece’s attempt to generate NFTs of songs without right-holders’ consent, point to the ways in which this technology is portrayed as threatening and subversive to commercial musicians (Blistein). Meanwhile, the Water and Music research DAO promises to incentivise a research community to “empower music-industry professionals with the knowledge, network and skills to do more collaborative and progressive work with technology” through NFT tokens and a DAO organisational structure (Hu et al.). The assumption in many early narratives of the ability of blockchain to provide systems of remuneration that musicians would embrace as inherently fairer is far from the reality of a popular discourse marked by increasing disdain and distrust, currently centred on NFTs as lacking in artistic merit, or even as harmful. We have seen all this talk before, of course, when jukeboxes and player pianos, film synchronisation, radio, recording, and other new communication technologies steered new paths for commercial musicians and promised magical futures. All of these innovations were met with intense scrutiny, cries of inauthentic practice, and resistance by incumbent musicians, but all were eventually sustained by the emergence of new forms of musical expression that captured the interest of the public. On the other hand, the road towards musical nirvana passes by not only the more prominent corpses of the Digital Audio Tape, SuperAudio, and countless recording formats, but if you squint and remember that technology is not always about devices or media, you can see the Secure Download Music Initiative, PressPlay, the International Music Registry, and Global Repertoire Databases in the distance, wondering if blockchain might correct some of the problems they dreamed of solving in their day. The NFT presents the artistic and cultural face of this dream of a musical future, and of course we are first seeing the emergence of old models within its contours. 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