Final Thesis: A real-world example of Transfer Pricing in Inner Source

Abstract: Inner source is the application of the open source paradigm within organizations. Inner source enables developers to contribute to software modules not only within their own organization, but also to those belonging to other organizations within the same company. This means from a developers point of view an increase of flexibility. However, for management, accounting and taxation transferring work between independent business entities can lead to significant challenges, as tax boundaries are crossed and therefore, transfer prices must be calculated. The main challenge here is, that calculating transfer prices for mixed software development is hard, as no exact data about work time is available.

To assign work time to single projects, a list of code contributions (commits) were analyzed to find logical structures. Based on this analysis, a work time calculation concept was developed. In addition to the concept development, a prototype for evaluation was developed. This implementation also includes an example transfer price calculation for taxation purposes, conducted by the Cost-Plus method.

Keywords: Inner source, transfer pricing, client-supplier relationship, software supply chain, commit transaction history, Cost Plus method

PDF: Master Thesis

Reference: Stefan Buchner. A real-world example of Transfer Pricing in Inner Source. Master Thesis. Friedrich-Alexander-Universität Erlangen-Nürnberg: 2021.