This position paper of the IBFD Academic Task Force (hereinafter IBFD Task Force) relates to the OECD's work on BEPS Action 1 and is devoted to withholding tax aspects. This position paper provides possible solutions to the challenges presented to the international tax regime by the digital...

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...

Following media reports on the low tax rates paid by some of the world's largest multinationals, international tax reform has moved to the top of policy-makers' agendas across the world. At the request of the G20, the OECD has designed an action plan to address what it calls base erosion and...