The Resource International taxation in an era of digital disruption : analyzing the current debate
International taxation in an era of digital disruption : analyzing the current debate
Resource Information
The item International taxation in an era of digital disruption : analyzing the current debate represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item International taxation in an era of digital disruption : analyzing the current debate represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- This paper sets out some considerations for U.S. international tax policymaking and international tax diplomacy in this uncertain environment. Part I briefly describes four disparate background considerations that should inform our thinking. Part IA describes the decline of the arm's-length standard, which underpinned our historic understandings about how to attribute profits as among entities within a multinational corporation (MNC). Part IB describes the relationship between the arm's-length standard, jurisdiction to tax, and the attribution of profits to permanent establishments (PE). It highlights that under OECD principles, attribution of profits to PEs is accomplished through application of the OECD's transfer pricing guidelines (TPG). Part IC recounts various acts of tax unilateralism abroad, often focused on the tech sector, and including the trend toward abandoning historic limits on jurisdiction to tax. Part ID describes the United States' 2017 tax reform in that global context, with a particular focus on the global intangible low-taxed income (GILTI) and the BEAT. Part II focuses on the European Commission and Her Majesty's Treasury (HMT) stated view that user participation should be acknowledged as a source of value creation in the digital economy and concludes that the user participation concept has application well beyond the so-called digital economy. Part III evaluates a version of the "marketing intangibles" idea and builds on the discussion about "where we go from here" in transfer pricing and concludes that splitting taxing rights over "excess" returns between the present transfer pricing system and a destination-based approached is complex. Part IV evaluates a version of a minimum tax system that combines inbound and outbound measures. Finally, the destination-based residual market profit allocation (DBRMPA) likely requires extensive tax harmonization and information exchange; more so than a minimum tax approach
- Language
- eng
- Label
- International taxation in an era of digital disruption : analyzing the current debate
- Title
- International taxation in an era of digital disruption : analyzing the current debate
- Language
- eng
- Summary
- This paper sets out some considerations for U.S. international tax policymaking and international tax diplomacy in this uncertain environment. Part I briefly describes four disparate background considerations that should inform our thinking. Part IA describes the decline of the arm's-length standard, which underpinned our historic understandings about how to attribute profits as among entities within a multinational corporation (MNC). Part IB describes the relationship between the arm's-length standard, jurisdiction to tax, and the attribution of profits to permanent establishments (PE). It highlights that under OECD principles, attribution of profits to PEs is accomplished through application of the OECD's transfer pricing guidelines (TPG). Part IC recounts various acts of tax unilateralism abroad, often focused on the tech sector, and including the trend toward abandoning historic limits on jurisdiction to tax. Part ID describes the United States' 2017 tax reform in that global context, with a particular focus on the global intangible low-taxed income (GILTI) and the BEAT. Part II focuses on the European Commission and Her Majesty's Treasury (HMT) stated view that user participation should be acknowledged as a source of value creation in the digital economy and concludes that the user participation concept has application well beyond the so-called digital economy. Part III evaluates a version of the "marketing intangibles" idea and builds on the discussion about "where we go from here" in transfer pricing and concludes that splitting taxing rights over "excess" returns between the present transfer pricing system and a destination-based approached is complex. Part IV evaluates a version of a minimum tax system that combines inbound and outbound measures. Finally, the destination-based residual market profit allocation (DBRMPA) likely requires extensive tax harmonization and information exchange; more so than a minimum tax approach
- Citation source
- In: International tax journal. - Riverwoods. - Vol. 45 (2019), no. 2 (March-April) ; p. 39-71
- http://library.link/vocab/creatorName
- Grinberg, I
- Geographic coverage
- International
- Language note
- English
- http://library.link/vocab/subjectName
-
- international taxation
- OECD Transfer Pricing Guidelines
- digital economy
- arm's length principle
- MNE
- PE
- tax reform
- GILTI
- BEAT
- user participation
- global minimum tax
- Label
- International taxation in an era of digital disruption : analyzing the current debate
- Label
- International taxation in an era of digital disruption : analyzing the current debate
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/International-taxation-in-an-era-of-digital/pFX2QfOH-Dw/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/International-taxation-in-an-era-of-digital/pFX2QfOH-Dw/">International taxation in an era of digital disruption : analyzing the current debate</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
