Tec(h)tonic Shifts: Taxing the “Digital Economy”
Tec(h)tonic Shifts: Taxing the “Digital Economy”

Author: Aqib Aslam

Publisher: International Monetary Fund

Published: 2020-05-29

Total Pages: 81

ISBN-13: 1513545973

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The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.

Taxing Tech : the Future of Digital Taxation
Taxing Tech : the Future of Digital Taxation

Author: L.V. Faulhaber

Publisher:

Published: 2019

Total Pages:

ISBN-13:

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In recent months, France and the United Kingdom have announced new taxes that are designed to target large multinational tech companies. In response, the United States has threatened trade sanctions. This article introduces the larger context of this controversy. The French and UK taxes are merely two examples of a much larger trend that has been taking place over the last several years, with countries around the world designing tax measures to target the so-called "digital economy" without ever determining what the digital economy is or how it differs from the rest of the economy. This article argues that, despite the many differences between the dozens of digital tax measures proposed or implemented over the past decade, two fundamental similarities link them together. First, all of these measures illustrate that countries believe that the current international tax system, which was designed in the 1920s under the auspices of the League of Nations, is outdated and needs to be reformed. Second, these digital tax measures focus on three elements of the existing system that countries believe need to be reformed: the physical presence requirement, the low tax rates available in some countries, and the ability of multinationals in particular to earn income without having a physical presence or to shift income to low-tax jurisdictions. Given these areas of agreement, this article considers the likelihood of countries reaching an international solution. This article acknowledges that an effective international solution - where countries agree to the necessary technical details and not just to high-level principles - faces serious challenges given that many countries now benefit from the current system. This article concludes that, if countries cannot agree to real international reform, then the international tax system will face many more years of countries imposing a cascade of inconsistent and overlapping digital tax measures on tech companies.

Tax Theory Applied to the Digital Economy
Tax Theory Applied to the Digital Economy

Author: Cristian Óliver Lucas-Mas

Publisher: World Bank Publications

Published: 2021-03-10

Total Pages: 217

ISBN-13: 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.

Taxation in the Digital Economy
Taxation in the Digital Economy

Author: Nella Hendriyetty

Publisher: Taylor & Francis

Published: 2022-07-11

Total Pages: 272

ISBN-13: 1000636496

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A robust and efficient tax administration in a modern tax system requires effective tax policies and legislation. Policy frameworks should cover all aspects of tax administration and include the essential processes of capturing, processing, analyzing, and responding to information provided by taxpayers and others concerning taxpayers’ affairs. By far the greatest challenges facing tax administrations in all countries are those posed by the continuing developments in the digital economy. Whereas societies are grappling to come to terms with the transitions from the third industrial or digital revolutions, revenue authorities grapple with the consequences for the sustainability of their tax bases and the efficient administration and collection of taxes. This book presents a critical review of the status of tax systems in Asia and the Pacific in the era of the digital economy. The book suggests how countries can maximize their domestic resource mobilization when confronted by the challenges that digitalization inevitably produces, as well as how they can best harness or take advantage of aspects of digitalization to serve their own needs. The full implications of the COVID-19 crisis are still too uncertain to predict, but it is clear that the crisis will accelerate the trend towards digitalization and also increase pressures on public finances. This, in turn, may shape the preference for, and the nature of, both multilateral and unilateral responses to the tax challenges posed by digitalization and the need to address them. This book will be a timely reference for those researching on taxation in digital economy and for policy makers.

Deconstruct to reconstruct
Deconstruct to reconstruct

Author: Ariel Andrés Sánchez Rojas

Publisher: Universidad de los Andes

Published: 2020-01-01

Total Pages: 78

ISBN-13: 9587749197

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Deconstruct to reconstruct seeks to use a modern benefit principle theory that will allow tax authorities to tax companies in the digital economy, assuring they pay taxes in the countries in which they operate. The emergence of a new business models such as app stores, online advertising, cloud computing, participative network platforms, high-speed trading, and online payment services has reshaped the global economy and made it difficult for tax authorities to determine what and where to tax. Technologies in the new digital economy make it possible for companies to operate in countries without being physically present. While companies such as Netflix, Google, and AirBnB provide services and earn profits in different countries, tax loopholes and intricate tax planning enable them to pay little-to-no taxes in many of these countries. For example, Netflix earned more than US$100 billion in Colombia in 2016, but it did not pay any direct or indirect taxes in the country. The absence of a specific tax or legal rule that targets digital companies has prevented Colombian tax authorities from taxing Netflix or any other company of the sort. Many tax authorities around the world have similar experiences.

The Challenge of the Digital Economy
The Challenge of the Digital Economy

Author: Francesco Boccia

Publisher: Springer

Published: 2017-02-08

Total Pages: 158

ISBN-13: 3319436902

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This volume presents contributions that analyse the extraordinary impact of digital technology on business, services, and the production of value in many sectors of the economy. At the heart of this book is the fact that the entire digital economy is now worth almost 6% of global GDP, and it continues to grow at an unprecedented rate. The volume covers the general debate on taxation and the digital economy with the chapters by Russo, Makiyama and Boccia, before completing the analysis with discussion of three national case studies covering the U.S. (Pagano), U.K. (Leonardi) and Italy (Boccia and Leonardi). Contributors are leading experts in the fields of taxation and the digital economy and contextualise the key issues surrounding the digitalisation of the economy from an international perspective.

Taxing the Digital Economy
Taxing the Digital Economy

Author: Craig Elliffe

Publisher: Cambridge University Press

Published: 2021-05-13

Total Pages: 355

ISBN-13: 1108485243

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Highly digitalised businesses threaten the viability of the international corporate tax system. Can a new system overcome these challenges?

Tax and the Digital Economy
Tax and the Digital Economy

Author: Werner C. Haslehner

Publisher:

Published: 2019

Total Pages: 0

ISBN-13: 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.

Taxation of the Digital Economy
Taxation of the Digital Economy

Author: Gillian Neky

Publisher: GRIN Verlag

Published: 2020-03-16

Total Pages: 122

ISBN-13: 3346131297

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Bachelor Thesis from the year 2019 in the subject Law - Tax / Fiscal Law, grade: A, University of Nairobi (School of Law), course: Dissertation, language: English, abstract: This dissertation explores the concept of the digital economy, its rapid growth, and the tax challenges it has introduced, both locally and internationally. It examines the general characteristic of a sovereign state and its inherent right to tax source on income generated within its jurisdiction. The dissertation attempts to investigate the taxability of the digital economy where business is conducted without the requirement of a physical presence, a pre-requisite for tax administration. How can states and especially Kenya detect permanent establishment, for purposes of tax administration, for an economy that is heavily reliant on intangible assets and a business model based on data, network effects, and user-generated content. It therefore, focuses and looks at the scope of Kenya’s legislative and policy frameworks and its effectiveness in taxing the digital economy. Digital businesses and especially multinational digital enterprises have been able to take advantage of the tax laws and policies that were written for an industrial age and are ill suited for today’s digital economy. The Action Plan on Base Erosion and Profit Shifting, by the Organization for Economic Co- operation and Development set out to answer the fundamental issues of BEPS (aggressive tax avoidance planning strategies), but it in itself fell short of expectations as it was not able to recommend practical, implementable solutions that would close the gaps that exist in the digital economy tax administration. The findings revealed that BEPS is not a single problem faced by all states but states face different BEPS problems and evaluate them from their own state-centred perspectives. Hence, the development of many interim measures by different states to tax the digital economy as the international community is still trying to come to a consensus on the possible, practical solutions. The current Kenyan tax framework on taxation of the digital economy is obscure as only recent Bills tabled in Parliament try and address the issue in depth. In light of the findings of this research, it was established that the problem is not so heavy on laws and regulation on taxation of goods sold electronically, but rather, implementation of the applicable laws where they exist. The paper finally recommends possible amendments to the Kenyan legal framework and the proposed amendments are assessed by means of comparison with what has taken place in other jurisdictions.