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International Tax Rules for the Digital Era

International Tax Rules for the Digital Era
Author: F. Chadwick
Publisher:
Total Pages:
Release: 2019
Genre:
ISBN:

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In this article, the author proposes a multilateral solution to the tax challenges of the digital economy.


European Value Added Tax in the Digital Era

European Value Added Tax in the Digital Era
Author: Marie Lamensch
Publisher:
Total Pages: 426
Release: 2014
Genre: Electronic commerce
ISBN: 9789087223458

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The Internet allows for instantaneous delivery of online supplies to consumers all over the world at any time of day or night. While the resulting "digital economy" offers great opportunities to suppliers and consumers, it also raises unprecedented challenges in the collection of value added taxes, particularly because of the intangible nature of online supplies, the relative anonymity of Internet users and the borderless nature of the e-marketplace. This book assesses the practical feasibility of existing EU VAT provisions on "electronically supplied services" and tests their compliance with the widely acknowledged OECD "Ottawa Taxation Framework" and the constitutional principle of non-discrimination as embedded in international and European economic law. It reveals major flaws in EU VAT legislation and the underlying OECD benchmark, given that both assume that online suppliers are able to carry out transaction-based verifications of the status and location of their customers in the same way as traditional suppliers. After discussing possible sources of inspiration for reforming the EU VAT treatment of online supplies (including the OECD "International VAT/GST Guidelines", the 2014 BEPS report on the "Challenges of the Digital Economy" and the recent European Commission Communication on a Digital Single Market Strategy for Europe), innovative and practical proposals are made on possible technology-based mechanisms that could be used in the future for the correct assessment and collection of value added tax on online supplies.


Digitalization and Taxation in Asia

Digitalization and Taxation in Asia
Author: Ms. Era Dabla-Norris
Publisher: International Monetary Fund
Total Pages: 75
Release: 2021-09-14
Genre: Business & Economics
ISBN: 1513577425

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Digitalization in Asia is pervasive, unique, and growing. It stands out by its sheer scale, with internet users far exceeding numbers in other regions. This facilitates e-commerce in markets that are large by international standards, supported by innovative payment systems and featuring major corporate players, including a number of large, home-grown, highly digitalized businesses (tech giants) that rival US multinational enterprises (MNEs) in size. Opportunity for future growth exists, as a significant population share remains unconnected.


Tax Sovereignty in the BEPS Era

Tax Sovereignty in the BEPS Era
Author: Sergio André Rocha
Publisher: Kluwer Law International B.V.
Total Pages: 338
Release: 2016-04-24
Genre: Law
ISBN: 9041167080

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The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.


Tax Theory Applied to the Digital Economy

Tax Theory Applied to the Digital Economy
Author: Cristian Óliver Lucas-Mas
Publisher: World Bank Publications
Total Pages: 217
Release: 2021-03-10
Genre: Business & Economics
ISBN: 1464816557

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Digital technology allows businesses to operate in a country without a physical presence, which poses challenges for traditional taxation. The digital debate focuses on direct taxation and the creation of new taxing rights arising from the tax claims of market jurisdictions on income obtained by foreign digital suppliers conducting business therein without any physical presence. Tax Theory Applied to the Digital Economy analyzes the tax-disruptive aspects of digital business models and reviews current tax initiatives in light of traditional tax theory principles. The analysis concludes that market countries’ tax claims are unsubstantiated and contravene the most basic foundations of tax theory, giving rise to a series of legal, economic, tax policy, and tax administration issues that policy makers cannot overlook. The authors propose establishing a digital data tax (DDT) that is a license-type consumption tax, rather than an income tax, on the international supply of Internet bandwidth to access digital markets. The DDT can be applied either globally or unilaterally, and could become a significant source of tax revenues for market jurisdictions. It is aligned with tax principles and it does not conflict with other tax initiatives: the DDT taxes foreign digital companies as consumers, while income tax proposals tax them as suppliers. The authors also propose creating a new global internet tax agency (GITA) under the auspices of the United Nations that would provide a neutral forum for political discussion and technical assistance in the area of digital taxation. The digital economy is a global phenomenon that requires a global solution: the creation of global taxing mechanisms and global institutions that provide technical assistance and support for successful global implementation. The book explains difficult technical concepts in plain language and contributes to the digital tax debate in a way that can be understood by anyone. Such understanding is essential to obtaining global support, achieving tax compliance, and fostering multilateral tax cooperation.


International Tax at the Crossroads

International Tax at the Crossroads
Author: Craig Elliffe
Publisher: Edward Elgar Publishing
Total Pages: 325
Release: 2023-12-11
Genre: Law
ISBN: 180088902X

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In light of the significant transformations affecting international tax in recent years, this book offers in-depth examinations on a series of key issues on the taxation of cross-border transactions. Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate.


Taxation in a Global Digital Economy

Taxation in a Global Digital Economy
Author: Ina Kerschner
Publisher: Linde Verlag GmbH
Total Pages: 519
Release: 2017-10-04
Genre: Law
ISBN: 3709409055

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Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law “Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.


Tax and the Digital Economy

Tax and the Digital Economy
Author: Werner C. Haslehner
Publisher:
Total Pages: 0
Release: 2019
Genre: Blockchains (Databases)
ISBN: 9789403503615

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Tax and the Digital Economy' provides a detailed analysis of the impact of the digitalization process on tax policy, tax administration and taxpayers. The increasingly digitalized global economy is undermining the usefulness of many traditional tax concepts. In addition to the issues of double taxation and double non-taxation, important questions arise concerning the allocation of taxing rights in respect of income from cross-border digital transactions. This is the first book to analyse what changes are possible, necessary and feasible in order to forestall the unravelling of the existing international tax framework and to provide guidance on ways to adapt national tax systems to a digitalized world.


International Taxation in an Era of Digital Disruption : Analyzing the Current Debate

International Taxation in an Era of Digital Disruption : Analyzing the Current Debate
Author: I. Grinberg
Publisher:
Total Pages:
Release: 2019
Genre:
ISBN:

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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.