This article focuses on the context of digitization in relation to the tax treatment of data. The authors, after discussing the importance of data to the growth of platform business models, seek to determine the extent to which data can serve as a reference point for taxation, the valuation problems that exist in this context, and the extent to which the arm's length principle, and by association the existing transfer pricing tools, are capable of reflecting: (i) data collection within a group, (ii) intra-group data sharing and (iii) data sales.