The Resource The allocation of taxing rights for highly digitalised business models : in search of a fair and neutral solution

The allocation of taxing rights for highly digitalised business models : in search of a fair and neutral solution

Label
The allocation of taxing rights for highly digitalised business models : in search of a fair and neutral solution
Title
The allocation of taxing rights for highly digitalised business models : in search of a fair and neutral solution
Creator
Subject
Language
eng
Summary
The aim of this article is to analyse the impact of highly digitalised business models on the distribution of taxing rights. The challenge encompasses the rules on the nexus and the allocation of profits, which require a modification to empower the source/market states and thus comply with the post-BEPS mandate of taxation in the territory where value is generated. Highly digitalised business models take advantage of data and user-generated content to create value and obtain profits. In the authorþs opinion, the solution to this problem must be respectful with the OECD Ottawa Taxation Framework Conditions for e-commerce, especially with tax neutrality and fairness. Given the difficult scenario of implementing a concept of virtual permanent establishment in the short and medium term, the author proposes three alternatives that respect tax neutrality and tax fairness, empowering the source/market states more:1. Creating a new income from the provision of advertising services in the Taxation Conventions 2. The expansive interpretation of the concept of royalties to include cloud-based services, and 3. A new Residual Profit Split Method that contains supply-side and demand-side factors
Citation source
In: Revista Técnica Tributaria : AEDAF - Madrid. - (2020), no. 128 ; p. 117-141
http://library.link/vocab/creatorName
Gómez Requena, J.Á
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • digital economy
  • allocation of taxing rights
  • nexus
  • allocation of profits
  • Unified Approach (OECD)
  • BEPS Project (OECD)
  • value creation
  • user participation
  • e-commerce
  • tax treaty
Label
The allocation of taxing rights for highly digitalised business models : in search of a fair and neutral solution
Instantiates
Publication
Label
The allocation of taxing rights for highly digitalised business models : in search of a fair and neutral solution
Publication

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