Taxation in a Global Digital Economy
1. Aufl. 2017
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1. S. 144Issues Raised by the Digital Economy in the Area of Direct Taxation
The digitalisation of the economy is nowadays regarded as one of the primary tax challenges as information and communication technologies have greatly changed business models and value creation chains. As observed by the OECD in its Base Erosion and Profit Shifting (BEPS) Project,
The digital economy is characterised by an unparalleled reliance on intangibles, the massive use of data (notably personal data), the widespread adoption of multi-sided business models capturing value from externalities generated by free products, and the difficulty of determining the jurisdiction in which value creation occurs.
These characteristics of the digital economy undoubtedly raise challenges for domestic and international tax policies.
In the area of direct taxation, the OECD identified three main tax issues raised by the digital economy: (i) whether the current rules to determine nexus with a jurisdiction for tax purposes are still appropriate given the reduced need for a physical presence in order to carry on business, (ii) whether any profits attributable to the remote gathering of data should be taxable in the State from whic...