International Taxation Of Cloud Computing
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International Taxation Of Cloud Computing
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Author : Alexander Weisser
language : en
Publisher: Éditions juridiques libres / Freier juristischer Verlag
Release Date : 2020-10-07
International Taxation Of Cloud Computing written by Alexander Weisser and has been published by Éditions juridiques libres / Freier juristischer Verlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-10-07 with Business & Economics categories.
Cloud computing may be borderless, but taxes are territorial. It is easy to imagine how the two concepts can clash. Much effort has gone into harmonizing tax rules across borders with the result that many jurisdictions have very similar tax rules. Even so, taxation remains a basic expression of national sovereignty. The goal of this thesis is to examine how international tax law applies to the cross-border cloud computing business. Both, multinational providers and customers of cloud computing services are analyzed. Reflecting three traditional areas of international tax scholarship, the goal could be stated in three questions. Which jurisdictions have the right to tax? What kinds of cloud computing transactions can be taxed? What amount of the profit is taxable? In more technical terms, this means enquiring into how the use of cloud computing affects the permanent establishment status of taxpayers, how the different kinds of cloud computing transactions are characterized under international double taxation treaties, and how the calculation of taxable cloud computing profit is affected by transfer pricing. In light of the current political events, the thesis also offers recommendations de lege lata through a systematic approach. Its first part assesses the current taxation of cloud computing. The second part evaluates whether the findings of this initial assessment conform to various superior principles of good rulemaking. It identifies which of the present tax rules ought to be adapted. The final part considers how the rules could be amended to become more compliant with the superior principles. In this way, Part I embodies the thesis, Part II the antithesis, and Part III seeks a synthesis.
International Taxation Of Cloud Computing Permanent Establishment Treaty Characterization And Transfer Pricing
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Author : A. Weisser
language : en
Publisher:
Release Date : 2020
International Taxation Of Cloud Computing Permanent Establishment Treaty Characterization And Transfer Pricing written by A. Weisser and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020 with categories.
Cloud computing may be borderless, but taxes are territorial. It is easy to imagine how the two concepts can clash. Much effort has gone into harmonizing tax rules across borders with the result that many jurisdictions have very similar tax rules. Even so, taxation remains a basic expression of national sovereignty. The goal of this thesis is to examine how international tax law applies to the cross-border cloud computing business. Both, multinational providers and customers of cloud computing services are analyzed. Reflecting three traditional areas of international tax scholarship, the goal could be stated in three questions. Which jurisdictions have the right to tax? What kinds of cloud computing transactions can be taxed? What amount of the profitt is taxable? In more technical terms, this means enquiring into how the use of cloud computing affects the permanent establishment status of taxpayers, how the different kinds of cloud computing transactions are characterized under international double taxation treaties, and how the calculation of taxable cloud computing profit is affected by transfer pricing. In light of the current political events, the thesis also offers recommendations de lege lata through a systematic approach. Its first part assesses the current taxation of cloud computing. The second part evaluates whether the findings of this initial assessment conform to various superior principles of good rulemaking. It identifies which of the present tax rules ought to be adapted. The final part considers how the rules could be amended to become more compliant with the superior principles. In this way, Part I embodies the thesis, Part II the antithesis, and Part III seeks a synthesis.
Taxing Global Digital Commerce
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Author : Arthur Cockfield
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-11-07
Taxing Global Digital Commerce written by Arthur Cockfield and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-11-07 with Law categories.
Digital commerce – the use of computer networks to facilitate transactions involving the production, distribution, sale, and delivery of goods and services – has grown from merely streamlining relations between consumer and business to a much more robust phenomenon embracing efficient business processes within a firm and between firms. Inevitably, the related taxation issues have grown as well. This latest edition of the preeminent text on the taxation of digital transactions revises, updates and expands the book’s coverage. It includes a detailed and up-to-date analysis of income tax and VAT developments regarding digital commerce under the OECD and G20 Base Erosion and Profit Shifting (BEPS) reforms. It explores the implications of digital commerce for US state sales and use tax regimes resulting from the 2018 US Supreme Court decision in Wayfair. It discusses cross-border tax in the United States while continuing to focus on tax developments throughout the world. Analysing the practical tax consequences of digital commerce from a multijurisdictional perspective, and using examples to illustrate the application of different taxes to digital commerce transactions, the book offers in-depth treatment of such topics as the following: how tax rules governing cross-border digital commerce are increasingly applied to all cross-border activities; how tax rules and institutional processes have evolved to confront challenges posed by digital commerce; how an emerging ‘tax war’ is developing whereby different countries are unilaterally imposing new tax rules on cross-border digital commerce; how technology enhances tax and cross-border tax information exchanges; how technology reduces both compliance and enforcement costs; cross-border consumption tax issues raised by cloud computing; and different approaches to the legal design of VAT place of taxation rules. The authors offer insightful views on the likely development of new approaches to taxing cross-border digital commerce. This edition, while building on the analysis of the relationship between traditional tax laws and the Internet in the first edition and its predecessors, contains a more explicit and systematic consideration of digital commerce issues and the ongoing policy responses to them. Tax professionals and academics everywhere will welcome the important contribution it makes towards the design of cross-border tax rules that are both conceptually sound and practical in application. ‘A tour de force … much larger and richer than its predecessors … a massive contribution to the growing literature on the taxation of e-commerce.’ – Rita de la Feria, British Tax Review ‘Provides important understandings for ongoing policy discussions … I would warmly recommend.’ – P. Rendahl, World Journal of VAT/GST Law
Taxation In A Global Digital Economy
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Author : Ina Kerschner
language : en
Publisher: Linde Verlag GmbH
Release Date : 2017-10-04
Taxation In A Global Digital Economy written by Ina Kerschner and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-10-04 with Law categories.
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 PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law “Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Tax And Technology
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Author : Annika Streicher
language : en
Publisher: Linde Verlag GmbH
Release Date : 2023-10-13
Tax And Technology written by Annika Streicher and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-10-13 with Law categories.
The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.
Tax And The Digital Economy
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Author : Werner Haslehner
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-05-01
Tax And The Digital Economy written by Werner Haslehner and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-05-01 with Law categories.
The increasingly digitalized global economy is undermining the usefulness of many traditional tax concepts. In addition to issues of double taxation and double non-taxation, important questions arise concerning the allocation of taxing rights in respect of income from cross-border digital transactions. This is the first book to analyse what changes are possible, necessary and feasible in order to forestall the unravelling of the existing international tax framework. Focusing in turn on the legal framework, specific proposals for adapting tax concepts for the digital economy, types of transactions and administrative issues such as those around data protection and digital currencies, the expert contributors discuss such challenges to taxation as the following: the pervasiveness of intangible assets; new value creation models; the ascendance of the sharing economy and digital services; virtual currencies; the importance of user participation for digital platforms; cloud computing; the impact of Big Data on tax enforcement; virtual business presence; and the influence of robotization. Throughout, the authors describe and analyse proposals made by the Organisation for Economic Co-operation and Development (OECD), the European Union (EU) and individual countries and their likely impact going forward. They also attend to the limits imposed on reform possibilities by public international law, EU law and constitutional law. It is generally acknowledged that there is a need to monitor how the digital transformation may be impacting value creation. This book is a key milestone toward developing a durable, long-term solution to the tax challenges posed by the digitalization of the economy. With its thorough scrutiny of proposals for digital services tax and virtual permanent establishments, insightful analysis of digital services and detailed description of the impact of big data on tax administration and taxpayer protection, it will quickly prove indispensable for tax practitioners and the international tax community more generally.
Taxing Global Digital Commerce
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Author : Arthur J. Cockfield
language : en
Publisher:
Release Date : 2015
Taxing Global Digital Commerce written by Arthur J. Cockfield and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with categories.
E-commerce -- the use of computer networks to facilitate transactions involving the production, distribution, sale, and delivery of goods and services in the marketplace -- has grown from merely streamlining relations between consumer and business to a much more robust phenomenon embracing efficient business processes within a firm and between firms. Inevitably, the related taxation issues have grown as well, particularly in the cross-border context. This latest edition of the preeminent text on the taxation of cross-border e-commerce transactions -- formerly titled Electronic Commerce and International Taxation (1999) and Electronic Commerce and Multijurisdictional Taxation (2001) -- revises, updates, and significantly expands the book's coverage, reorganizing its presentation and adding several new chapters. It includes a detailed and up-to-date analysis of VAT developments regarding e-commerce, and explores the implications of e-commerce for the US state and local sales and use tax regime as well as with respect to US and foreign international income tax laws. Analysing the practical tax consequences of e-commerce from a multijurisdictional perspective and using examples to illustrate the application of different taxes to e-commerce transactions, the book offers in-depth treatment of such topics as: (a) how tax rules governing cross-border e-commerce are increasingly applied to all cross-border activities; (b) how tax rules and institutional processes have evolved to confront challenges posed by e-commerce; (c) how technology enhances cross-border tax information exchanges; (d) how technology reduces compliance and enforcement costs; (e) US state and local sales and use tax issues raised by cloud computing; and (e) different approaches to the legal design of VAT place of taxation rules. This edition, while building on the analysis of the relationship between traditional tax laws and the Internet in earlier editions, contains a more explicit and systematic consideration of e-commerce issues as well as the ongoing policy responses to them. This SSRN post contains the book's Table of Contents, Preface, and Chapter 1.
Tax Challenges Arising From Digitalisation Interim Report 2018
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Author : Collectif
language : en
Publisher: OECD
Release Date : 2018-05-29
Tax Challenges Arising From Digitalisation Interim Report 2018 written by Collectif and has been published by OECD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-05-29 with Business & Economics categories.
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.
International Taxation Of Income From Services Under Double Taxation Conventions
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Author : Marta Castelon
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
International Taxation Of Income From Services Under Double Taxation Conventions written by Marta Castelon and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-24 with Law categories.
The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.
Launching A Digital Tax Administration Transformation
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Author : Asian Development Bank
language : en
Publisher: Asian Development Bank
Release Date : 2022-04-01
Launching A Digital Tax Administration Transformation written by Asian Development Bank and has been published by Asian Development Bank this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-04-01 with Business & Economics categories.
This publication provides an overview of issues and areas that policymakers from members of the Asian Development Bank would want to be familiar with when embarking on planning and implementing a digital transformation of tax administration. Key considerations include reasons for undertaking a transformational reform, the elements needed to build a strategy and implementation plan (digital road map), risks and chalenges, and possible impacts. The report brings together a basic assessment framework to support the initiation of the planning process and an approach to effective implementation of “the tax administration of the future.”