The Resource A long-term solution for taxing digitalized business models : should the permanent establishment definition be modified to resolve the issue or should the focus be on a shared taxing rights mechanism?

A long-term solution for taxing digitalized business models : should the permanent establishment definition be modified to resolve the issue or should the focus be on a shared taxing rights mechanism?

Label
A long-term solution for taxing digitalized business models : should the permanent establishment definition be modified to resolve the issue or should the focus be on a shared taxing rights mechanism?
Title
A long-term solution for taxing digitalized business models : should the permanent establishment definition be modified to resolve the issue or should the focus be on a shared taxing rights mechanism?
Creator
Subject
Language
eng
Summary
The article discusses how a jurisdiction can tax a business entity based on digital business models. It has been argued that creating a new nexus by introducing a digital permanent establishment (PE) or a significant economic presence test seems to be an ideal long-term solution. By referring to the work on BEPS Action 7, the authors argue that not all states like to amend the PE definition. Moreover, for states that adopted the amendments to counter artificial avoidance of the PE status, the authors argue that the profits attributable to the PE will be restricted to the limited functions performed by the PE or, when the PE does not perform any functions, the profits attributable will be negligible. As a solution the authors propose new profit allocation rules (such as the profit splitting method)
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 46 (2018), no. 6/7 ; p. 476-494
http://library.link/vocab/creatorName
  • Spinosa, L
  • Chand, V
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • digital economy
  • PE
  • digital PE
  • significant digital presence
  • significant economic presence
  • allocation of profits
Label
A long-term solution for taxing digitalized business models : should the permanent establishment definition be modified to resolve the issue or should the focus be on a shared taxing rights mechanism?
Instantiates
Publication
Label
A long-term solution for taxing digitalized business models : should the permanent establishment definition be modified to resolve the issue or should the focus be on a shared taxing rights mechanism?
Publication

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