Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS) project of 15 reports.  In 2005, ten years before the BEPS reports, the OECD published E-commerce: Transfer Pricing and Business Profits Taxation to…

The Spanish government approved, on 18 February 2020, a bill for a digital service tax (DST) for discussion by the parliament[1]. The current government has a majority consensus on the new tax with the rest of the political parties, and it is, therefore, very likely to pass the bill. Background: EU Proposal The Spanish Digital…

We applaud the OECD’s 15–year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of multinational enterprises’ business models and the evolution of cross-border ecommerce. We support the 6 November 2019 comments of Dr. Lorraine Eden, our colleague, and Dr. Oliver Treidler, that…

The digital economy is faced with major challenges for the international tax system since the traditional tax rules seem to be insufficiently well designed to govern new ways of conducting businesses and unsuitable for accurately detecting and allocating the value created from digitalised business models.[1] This situation has triggered a political and academic discussion about…

In my International Taxation class tomorrow (October 10th) we are going to discuss the  OECD’s “Unified Approach” released a day earlier on October 9, 2019.  Given the keen interest generated by digital taxation and the allocation of profits/losses generated therefrom, I thought it of interest to the Kluwer International Tax readers that I share my…

Taxation of the digital economy is one of the more difficult and contentious issues in international taxation. There are several strands to this complexity. One strand is profit attribution for enterprises trading across different tax jurisdictions. Yet, several countries have introduced or propose to introduce a tax on MNEs in the digital sector known as…