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Disruptive Profit Allocation Methods for Disruptive Businesses?! (Part I)
Different Approaches for Taxing the Digitalised Economy
In February 2019, the OECD launched a Consultation Document on the digitalisation of the economy indicating a way forward based on two pillars (revised nexus and profit allocation rules, and global anti-base erosion approaches), followed by a Public Consultation on March 15th and 16th, 2019. Finally, the OECD published a Programme of Work to develop a consensus solution to the tax challenges arising from the digitalisation of the economy on May 31st, 2019.
The first part of this article discusses the different approaches for taxing the digitalised economy embedded in those documents. The second part of the article will contain comments on the OECD approaches and discuss alternatives brought forward including suggested approaches from the UN and the IMF.
1. Introduction: What Has Happened Until Now?
In October 2015, the OECD published the BEPS action 1 report on tax challenges arising from digitalisation. In September 2017, G20 countries decided to re-ignite the OECD digital project, which was soon to be followed by a call for input and a public consultation. In March 2018, also as a result of this call for input and contributions received, the OECD released an Interim Report which was...