What made writing Transfer Pricing in the Age of Data Centers particularly interesting for me was the public-policy dimension, which I think deserves much more attention. This is not simply a developed-versus-developing-country issue. India has developed its own regime for data centres; Singapore and Malaysia are major Asian hubs; Saudi Arabia and the UAE are investing heavily in digital infrastructure. And the same question arises within the United States, where states compete for data centres through tax exemptions, infrastructure support and other incentives. That makes the sequencing important. Public policy comes first. A jurisdiction has to decide what it is prepared to subsidise, what the data centre should pay for, and what return the public should receive for providing scarce power, water, land and grid capacity. Transfer pricing can then allocate income within the multinational group, but it cannot be expected to recover value that public policy has chosen not to price or You can read the published version here: bit.ly/4xxQJ4X. @IBFD_on_Tax @TaxPolicyCenter @TaxNotes @IncomeTaxIndia