Describing Globally Distributed Software Architectures for Tax Compliance

Background: The company-internal reuse of software components owned by organizational units in different countries constitutes an implicit licensing across borders, which is taxable. This makes tax authorities a less known stakeholder in software architectures. Objective: Therefore, we investigate how software companies can describe the implicit license structure of their globally distributed software architectures to tax authorities. Method: We develop a viewpoint that frames the concerns of tax authorities, use this viewpoint to construct a view of a large-scale microservice architecture of a multinational enterprise, and evaluate the resulting software architecture description with a panel of four tax experts. Results: The panel found our proposed architectural viewpoint properly and sufficiently frames the concerns of taxation stakeholders. However, unclear jurisdictions of owners and potentially insufficient definitions of code ownership and software component introduce significant noise to the view that limits the usefulness and explanatory power of our software architecture description. Conclusion: While our software architecture description provides a solid foundation, we believe it only represents the tip of the iceberg. Future research is necessary to pave the way for advancements in tax compliance within software engineering.