Functions, assets and risks in transfer pricing mirror the classical economic factors of land, labour and capital. Famously, Thomas Piketty has written about the dominant role of capital in income equality in our age. However, from significant people’s functions in 2010 to DEMPE in BEPS Actions 8-10, the recent evolution of thinking around transfer pricing has increasingly emphasized functions, i.e. labour, while relegating capital to a supporting or secondary role in the attribution of profits. The authors examine the treatment of capital in transfer pricing, comparing and contrasting between the financial services and non-financial services sectors, with the hope of contributing to a more balanced appreciation of the role of capital and the need for future guidance in this area.