Taxing Collaborative Software Engineering

Michael Dorner, Darja Smite, Ehsan Zabardast, Daniel Mendez, Krzysztof Wnuk, Maximilian Capraro, Oliver Treidler and Tom-Eric Kunz

IEEE Software,

2024 · doi:


The engineering of complex software systems is often the result of a highly collaborative effort. However, collaboration within a multinational enterprise has an overlooked legal implication when developers collaborate across national borders: It is taxable. In this article, we discuss the unsolved problem of taxing collaborative software engineering across borders. We (1) introduce the reader to the basic principle of international taxation, (2) identify three main challenges for taxing collaborative software engineering making it a software engineering problem, and (3) estimate the industrial significance of cross-border collaboration in modern software engineering by measuring cross-border code reviews at a multinational software company.