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This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...
Persistent link: https://www.econbiz.de/10011334067
The use of information and communication technologies (ICT) within multinational groups leads to a rising number of intragroup cross-border transactions. At the same time, transactions and the organisational structures of affiliated groups become more and more specific and, thus, less...
Persistent link: https://www.econbiz.de/10011448681
In its strongest statement yet on progressive tax reform, the UN has recently called on countries to introduce a global carbon tax and financial transaction tax (FTT). In my recent article entitled Global Taxation of Cross Border E-commerce Income (31 Virginia Tax Review 639 (Spring 2012)), I...
Persistent link: https://www.econbiz.de/10014157407
This article is discussing comparative approaches to the definitions of the e-commerce and e-payment. The international taxation systems, direct and indirect taxation, entity isolation and “arm's length principle” applied to entity isolation problem, resident-based and source-based taxation,...
Persistent link: https://www.econbiz.de/10012971776
This chapter is divided into three main parts: 1) international tax law, 2) domestic tax law, and 3) tax and regulation. The first part deals with the international tax system and the way it has been affected by technology. This part will focus on income tax. Existing rules of nexus,...
Persistent link: https://www.econbiz.de/10013249444
The advent of the digital economy has had profound implications for taxation. Tax systems have been forced to adapt as they become increasingly unsuited for the realities of modern commerce. While Singapore has largely followed international developments, particularly in the area of...
Persistent link: https://www.econbiz.de/10014343661
Before COVID-19 arrived, policymakers from around the world were busy working on the makings of a new global tax … consensus to reflect structural changes in the world economy as a result of the rise of digitalization. COVID-19 disrupted this … contemporary context for excess profits taxes is fundamentally global today, in a way that excess profit taxation during the world …
Persistent link: https://www.econbiz.de/10012830027
This volume of the Cahiers has been published by Sdu, The Netherlands, on behalf of the International Fiscal Association (IFA). Once a year the Cahiers de Droit Fiscal International are published and distributed free to all the members of the Association.00These Cahiers contain a wealth of...
Persistent link: https://www.econbiz.de/10011881175
Persistent link: https://www.econbiz.de/10011961843
The use of digital services is largely non-rival. This paper argues that vanishing marginal costs of supply change policy incentives. Small countries are incentivized to tax the import of digital services. In fact, various countries have already moved towards expanded source taxation of online...
Persistent link: https://www.econbiz.de/10012105550