The article discusses how global digitalization has changed the way companies shift their profits to lower tax jurisdictions. The OECD introduced the BEPS initiative in 2013 to tackle this issue. The focus shifted towards the profit-split method for intangible transactions, but in 2018, a revised guidance was issued. In 2019, the Inclusive Framework called for a better transfer pricing method beyond the arm's length principle. This has led to uncertainty in the tax system. Alternative methods like the value created method are being considered to address the loopholes in the current tax evaluation system.