Tec(h)tonic Shifts: Taxing the “Digital Economy”

Tec(h)tonic Shifts: Taxing the “Digital Economy” PDF Author: Aqib Aslam
Publisher: International Monetary Fund
ISBN: 1513545973
Category : Business & Economics
Languages : en
Pages : 81

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Book Description
The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.

Tec(h)tonic Shifts: Taxing the “Digital Economy”

Tec(h)tonic Shifts: Taxing the “Digital Economy” PDF Author: Aqib Aslam
Publisher: International Monetary Fund
ISBN: 1513545973
Category : Business & Economics
Languages : en
Pages : 81

Get Book Here

Book Description
The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.

Recent Trends In Transfer Pricing Intangibles, GAAR and BEPS

Recent Trends In Transfer Pricing Intangibles, GAAR and BEPS PDF Author: Ravikant Gupta
Publisher: Bloomsbury Publishing
ISBN: 938614171X
Category : Business & Economics
Languages : en
Pages : 474

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Book Description
About the book The growing importance of the intangible assets in the global economy coupled with expanding international intra-firm trade, has meant that transfer pricing issues concerning intangibles have assumed critical importance for both the Multi National Enterprises as well as Tax authorities. The identification, accounting & valuation of intangibles is a challenging and evolving field. This volume details the various such issues and concerns from both industry and revenue perspective. Further, the contemporary issues of digital economy, tax planning, BEPS, GAAR have also been extensively dealt with. Key features · Explains in detail the meaning of various types of intangibles as defined in Income Tax Act. · Discusses the various possible methodologies for valuing the intangibles including the typical and residual methods · Accounts for all the relevant changes suggested by the OECD in the BEPS Action Point 8-10 report regarding intangibles · Valuation of Highly Uncertain as well Hard-to-Value Intangibles · Relevant Features of and taxation challenges posed by Digital economy · Various possible techniques of Tax Planning adopted by the Multi-national Enterprises · All the BEPS Action Point Reports along with recommendations as adopted globally as well as in India including Thin Capitalisation, PoEM, Equalisation Levy, amended DTAAs with Mauritius, Cyprus & Singapore {Updated upto Finance Bill, 2017 (India)} · Transfer Pricing Aspects of CCAs, Intra-group Services & Business Restructuring including issue of indirect transfers · Discussion on General Anti Avoidance Rules, to be implemented in India from 01/04/2017 · Famous and important global and Indian case laws with regard to intangibles · Detailed discussion on issue of AMP expenses & marketing intangibles

Humanizing the Digital Economy

Humanizing the Digital Economy PDF Author: Victor Glass
Publisher: Springer Nature
ISBN: 3031375076
Category : Computers
Languages : en
Pages : 374

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Book Description
The Coding Revolution—a combination of the Digital Revolution and genetic engineering—has had a destructive effect on society. It has created a platform for extreme views that is loosening our economic, cultural, and political moorings. This book provides a systematic approach to policy and management to promote societal collaboration and unity. It describes the changes caused by the Digital Age, including the Internet, Artificial Intelligence, and various other technologies. The author then offers a new framework, Religious Humanism, which incorporates covenants of the Bible, the US Constitution and other sources of wisdom to foster collaboration and create a revitalized and inclusive global society. Narrative and analytical tools are offered as well as case examples.

Tectonic Politics

Tectonic Politics PDF Author: Nigel Gould-Davies
Publisher: Brookings Institution Press
ISBN: 0815737149
Category : Political Science
Languages : en
Pages : 190

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Book Description
Political risk now affects more markets and countries than ever before and that risk will continue to rise. But traditional methods of managing political risk are no longer legitimate or effective. In Tectonic Politics, Nigel Gould-Davies explores the complex, shifting landscape of political risk and how to navigate it. He analyses trends in each form of political risk: the power to destroy, seize, regulate, and tax. He shows how each of these forms reflects a deeper transformation of the global political economy that is reordering the relationship between power, wealth, and values. In a world where everything is political, the craft of engagement is as important as the science of production and the art of the deal. The successful company must integrate that craft—the engager's way of seeing and doing—into strategy and culture. Drawing on a career in academia, business, and diplomacy, Gould-Davies provides corporate leaders, scholars, and engaged citizens with a groundbreaking study of the fastest-rising political risk today. “As tectonic plates shape the earth,” he writes, “so tectonic politics forges its governance.”

Taming Corporate Power in the 21st Century

Taming Corporate Power in the 21st Century PDF Author: Gerald F. Davis
Publisher:
ISBN: 1009089277
Category : Business & Economics
Languages : en
Pages : 90

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Book Description
There is broad consensus across the political spectrum in the US that monopolistic corporations - particularly Big Tech companies -- have grown too powerful, and that we need to revive antitrust to take on the 'curse of bigness.' But both the diagnosis and the cure are rooted in an outdated understanding of how the American economy is organized. Information and communication technologies have fundamentally altered the markets for capital, labor, supplies, and distribution in ways that undermine the basic categories we use to understand the economy. Nationality, industry, firm, size, employee, and other fundamental terms are increasingly detached from the operations of the economy. If we want to understand and tame the new sources of economic power, we need a new diagnosis and a new set of tools.

Shift

Shift PDF Author: Haydn Shaughnessy
Publisher:
ISBN: 9781941420034
Category :
Languages : en
Pages : 378

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Book Description
"Shift is a powerful work full of insight stemming from Haydn Shaughnessy's formidable powers of observation and research." -Patrick Reynolds, Chief Strategy Officer, Triton Digital There is a new economy growing all around us. Whether you own a business or lead one, are a freelancer or employee, are beginning a career or working your way up the ladder, Shift provides a guide to the major changes that are reshaping the economy and our lives. Haydn Shaughnessy spells out why the current economic transformation is different from anything that preceded it. The digital economy is not just about new technology. Dramatic changes are taking place in how people work together, how they think about society and wealth, and the risks and options they face in employment and business. Haydn draws a detailed picture of new power groups that are driving this new economy-turning rapid innovation into real-time disruption. These power groups are rendering governments increasingly irrelevant in their traditional job creation and economic growth roles, and putting more demands on companies, online communities, and individuals. Shift is essential reading for anyone who wants to understand the digital revolution that is changing economic policy, work, and prosperity for the vast majority of people. It is a survival guide for the 21st-century economy.

Tax Recommendations and Reforms Proposed by the Commission on the Twenty-First Century Economy

Tax Recommendations and Reforms Proposed by the Commission on the Twenty-First Century Economy PDF Author: California. Legislature. Senate. Committee on Revenue and Taxation
Publisher:
ISBN:
Category : California
Languages : en
Pages : 378

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Book Description


The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option

The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option PDF Author: Richard Krever
Publisher: Kluwer Law International B.V.
ISBN: 9403506156
Category : Law
Languages : en
Pages : 314

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Book Description
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246

Florida State University Law Review

Florida State University Law Review PDF Author: Florida State University. College of Law
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 660

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Book Description


Rethinking Subnational Taxes

Rethinking Subnational Taxes PDF Author: Mr.Richard Miller Bird
Publisher: International Monetary Fund
ISBN: 1451858035
Category : Business & Economics
Languages : en
Pages : 55

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Book Description
The assignment of revenues in most developing and transitional countries to the central government has arguably facilitated irresponsible behavior by some subnational governments. One way to relieve this problem is to strengthen subnational tax regimes. The paper proposes two approaches to accomplish such strengthening in developing countries. The first—most applicable to large countries with important regional governments—is to establish subnational value-added taxes (VATs); the second is to replace the various unsatisfactory state and local taxes imposed on business by a low-rate value-added tax levied on the basis of income (production, origin) rather than consumption (destination).