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Taxation in a Global Digital Economy

Schriftenreihe IStR Band 107

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Ina Kerschner(Hg.), Maryte Somare(Hg.), Taxation in a Global Digital Economy (2017), Linde Verlag, 1210 Wien, ISBN: 9783709409046

Beschreibung / Abstract

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 Policy

  • Tax Treaty Law

  • Transfer Pricing

  • Indirect Taxation Issues

  • EU Law



“Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.

Beschreibung

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 Policy· Tax Treaty Law· Transfer Pricing· Indirect Taxation Issues· EU Law “Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.

Inhaltsverzeichnis

  • BEGINN
  • Series Editor’s Preface
  • Editors’ Preface
  • List of Authors
  • Subtopic 1: International Tax Policy
  • International Initiatives in Addressing Challenges Posed by the Digital Economy
  • Tax Treaty Policy in Addressing Challenges Posed by the Digital Economy
  • CFC Rules as a Measure to Address BEPS Opportunities in a Digital Economy
  • The Taxation of ‘Sharing Economy’ Activities
  • Subtopic 2: Tax Treaty Law
  • The Concept of Corporate Tax Residence in Light of the Digital Economy
  • Modification of a Taxable Nexus to Address the Tax Challenges of the Digital Economy
  • The Concept of a Server PE in the Digital Economy
  • The Attribution of Income to a Digital Permanent Establishment
  • Challenges Posed by Permanent Establishment-Exemptions in the Context of the Digital Economy
  • The Anti-Fragmentation Rule as an Instrument to Tackle BEPS Problems in the Digital Economy
  • Issues Regarding the Characterisation of Income Derived by Digital Enterprises
  • Tax Treaty Issues in Taxing Digital Dependent Labour Assignments
  • Subtopic 3: Transfer Pricing
  • Value Creation in the Digital Economy
  • Transfer Pricing of Intangibles in the Digital Economy
  • Exposing BEPS Risks of the Digital Business Models by Means of CbC Reports
  • Subtopic 4: Indirect Taxation Issues
  • E-Books and VAT
  • Cloud Computing Services and VAT
  • The Treatment of Bitcoin Transactions for Indirect Tax Purposes
  • EU OSS & MOSS: A Solution to the Challenges of the Digital Economy?
  • Subtopic 5: EU Law
  • ‘Patent Boxes’ and Their Compatibility with European Union State Aid Rules
  • Apple – Ireland and European Union State Aid Rules

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