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...

In the wake of ex-NSA contractor Edward Snowden’s surveillance revelations to the global public, and despite an unimpeded cross-border data flow and knowledge transfer being a pre-requisite for the development of the digital economy, governments around the world are increasingly tending to...