SIAI Research Working Paper Referenced in EY BorderCrossings Webcast on AI and Transfer Pricing
Published
Ernst & Young LLP referenced an SIAI Research working paper in its September 24, 2026 BorderCrossings webcast, “Transfer pricing in the age of digital transformation.”
The webcast examined how digital transformation and artificial intelligence are reshaping global value chains and creating new transfer-pricing, tax and controversy considerations for multinational businesses. Its agenda included the AI value chain, profit allocation, cross-border tax considerations, and the implications of AI-enabled operating models.
During the presentation, EY referenced Professor Keith Lee’s SIAI Research working paper, “[AI and Tax] Data-Center Taxation and the Geography of AI Value,” published in the SIAI Research Working Paper Series in July 2026. The webcast incorporated the paper’s seven-layer AI value-stack framework to illustrate how economic value is distributed across semiconductors, data-center infrastructure, energy, cloud services, foundation models, software and data, and adopting firms and end customers.
- E&Y webcast: BorderCrossings with EY TP and tax professionals – Sept 2026 | EY - US
- Reference page
The framework emphasizes that the data center itself represents only one node within a broader AI value chain, and that value creation and value capture may shift across different layers over time. This distinction is particularly relevant for emerging questions in transfer pricing, international taxation and the geographic allocation of AI-related economic value.
Following the webcast, EY shared the presentation materials with SIAI for institutional records and noted that the research had helped frame the discussion.
The reference represents another example of SIAI Research being used in professional discussions at the intersection of artificial intelligence, economics and taxation.
