Ehsan Zabardast

The internal reuse of software components owned by organizational units in different countries constitutes an implicit form of licensing that may be taxable under international regulations, making tax authorities an often overlooked stakeholder in software architecture. This study explores to what extent a deliberately minimal software architecture description can make implicit cross-border licensing visible and interpretable for tax experts. We define a deliberately minimal architecture viewpoint based on components, dependencies, ownership, and jurisdiction and construct a view for a large-scale industrial microservice software system comprising 2518 components and 16,533 dependencies. The resulting architecture description is evaluated in a judgment study with four experienced tax auditors and tax advisors using semi-structured interviews. The results show that the software architecture description provides a structured, evidence-based starting point for identifying cross-border reuse and supports tax audit discussions. However, experts report limitations, including mismatches between software engineering and legal notions of ownership, unclear jurisdictional assignments, and the perceived risk of interpreting dependency counts as indicators of economic value. These limitations persist despite detailed architectural data. We conclude that software architecture descriptions can expose structurally relevant reuse relationships but cannot, on their own, support the legally meaningful interpretations required for tax assessment, indicating a fundamental mismatch between architectural abstractions and taxation concepts.

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.

Context: Developing software-intensive products or services usually involves a plethora of software artefacts. Assets are artefacts intended to be used more than once and have value for organisations; examples include test cases, code, requirements, and documentation. During the development process, assets might degrade, affecting the effectiveness and efficiency of the development process. Therefore, assets are an investment that requires continuous management. Identifying assets is the first step for their effective management. However, there is a lack of awareness of what assets and types of assets are common in software-developing organisations. Most types of assets are understudied, and their state of quality and how they degrade over time have not been well-understood. Method: We perform a systematic literature review and a field study at five companies to study and identify assets to fill the gap in research. The results were analysed qualitatively and summarised in a taxonomy. Results: We create the first comprehensive, structured, yet extendable taxonomy of assets, containing 57 types of assets. Conclusions: The taxonomy serves as a foundation for identifying assets that are relevant for an organisation and enables the study of asset management and asset degradation concepts.