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Taxing the Digital Economy: Theory, Policy and Practice [Kietas viršelis]

  • Formatas: Hardback, 250 pages, aukštis x plotis x storis: 150x230x25 mm, weight: 670 g, Worked examples or Exercises
  • Serija: Cambridge Tax Law Series
  • Išleidimo metai: 13-May-2021
  • Leidėjas: Cambridge University Press
  • ISBN-10: 1108485243
  • ISBN-13: 9781108485241
Kitos knygos pagal šią temą:
Taxing the Digital Economy: Theory, Policy and PracticeDidesnis paveikslėlis
  • Formatas: Hardback, 250 pages, aukštis x plotis x storis: 150x230x25 mm, weight: 670 g, Worked examples or Exercises
  • Serija: Cambridge Tax Law Series
  • Išleidimo metai: 13-May-2021
  • Leidėjas: Cambridge University Press
  • ISBN-10: 1108485243
  • ISBN-13: 9781108485241
Kitos knygos pagal šią temą:
Pastovi nuoroda: https://www.kriso.lt/db/9781108485241.html
Raktažodžiai:
"In 2018, the total global e-commerce market worth roughly USD 7.7 trillion. Despite the size of this economy and its extraordinary growth rate, many multinational companies paid little tax in the countries in which they did business. This is not a problem that can be ignored. Digital companies grow much faster than other firms. In 2006, technology companies accounted for 7% of the top 20 market capitalisation of EU companies, by 2017 this had grown to 54%. Digital companies rely less on physical presence utilising intellectual property, enabling companies to set up a business far away from their consumers, where some of the actual economic activity takes place. Most concerning is the fact that, on average, digitalised businesses face an effective tax rate of only 9.5% compared to 23.2% for traditional business models.1 Consequently, there is widespread concern from governments and the public about the low level of income tax paid by companies operating in the digital economy"--

Recenzijos

'Professor Elliffe comprehensively discusses the most controversial subject of the current global tax conversation, which challenges the roots of the traditional international tax system. A fine work and a must-read book.' Robert Danon, Professor of Law at the University of Lausanne and Chairman of the Permanent Scientific Committee of the International Fiscal Association (IFA) 'This outstanding book covers the hottest topic in international taxation, and both countries and international organizations are in the process of rapidly changing the rules. Under these circumstances, plus a global pandemic, it is very hard to do what Craig Elliffe has successfully done: to produce an eminently readable, short, and accurate summary of both the current state of affairs and its historical origins, going back a century to the original 1920s compromise that created the international tax regime (ITR).' Reuven Avi-Yonah, Irwin I. Cohn Professor of Law, University of Michigan 'A truly global tax book - presenting a holistic view of the tax issues of the digital economy built on wide-ranging comparative and foundational research.' Wolfgang Schön, Director of The Max Planck Institute for Tax Law and Public Finance, Munich 'Taxation of the digital[ ised] economy is the current focus of the international tax world's attention. The first part of this book explains the historical background and the challenges to the current tax regime. The second part examines the OECD proposals (as they stood in early 2020), and various alternatives including DBCFTs and DPTs, as well as unilateral DSTs. Whatever becomes of the OECD project, the discussion here will remain valuable as a resource and guide.' Philip Baker QC, Gray's Inn and Oxford University, author of Double Taxation Conventions 'Professor Craig Elliffe's book is one of the first independent and comprehensive works of scholarship to seriously analyse these challenges, the political process that dominates the work on them within the international tax regime, and the concrete proposals to resolve them. The book is an important and timely resource for whomever wishes to study the issue.' Yariv Brauner, BTR 'There is no 'hotter' topic on the agenda of the international tax regime than the taxation of the digital economy The book is an important and timely resource for whomever wishes to study the issue.' Yariv Brauner, British Tax Review

Daugiau informacijos

Highly digitalised businesses threaten the viability of the international corporate tax system. Can a new system overcome these challenges?
List of Figures
x
Preface xi
Acknowledgements xiv
Part I
1 Taxing Cross-Border Business Income
3(54)
1.1 What Is Cross-Border Taxation?
3(2)
1.2 Fundamental Concepts of International Taxation: Residence and Source
5(4)
1.3 The History of International Double Taxation: The "1920s Compromise"
9(7)
1.4 Justifying Source and Residence Taxation
16(18)
1.5 The Benefit Theory and Its Relationship to Value Creation
34(7)
1.6 Observations about Source and Residence Taxation in the Context of Cross-Border Business
41(5)
1.7 Exploring the Limits of Domestic Source-Based Taxation
46(9)
1.8 Base Erosion and Profit Shifting and the Emerging Threat of Digitalisation in Business
55(2)
2 The Development of Digital Business
57(27)
2.1 The Dynamic Information Age
57(6)
2.2 The Defining Characteristics of Digital Markets
63(5)
2.3 Doing Business Using a Multi-sided Platform
68(8)
2.4 Using the Reseller Model
76(1)
2.5 Using Vertically Integrated Firms
77(1)
2.6 Using Firms That Are Input Suppliers
77(1)
2.7 Observations about the Key Characteristics of Digitalised Business Models
77(7)
3 Challenges to the Tax System Posed by the Digitalisation of Business
84(28)
3.1 Introduction to the Challenges
84(5)
3.2 The Vanishing Ability to Tax Business Profits
89(8)
3.3 The Use of Data, the Contribution of Users and the Measurement of Their Value
97(5)
3.4 The Reliance on, and Mobility of, Intellectual Property
102(2)
3.5 The Characterisation of Transactions and Income
104(2)
3.6 The Failure of Transfer Pricing with Certain Multinational Enterprises and Their Transactions
106(2)
3.7 The Inadequacy of Residence-Based Taxation
108(2)
3.8 Competition by States
110(2)
4 Responding to the Challenges: Legal Constraints on Any Changes to the Current Framework
112(55)
4.1 Introduction
112(1)
4.2 International Tax at the Crossroads
113(6)
4.3 Interim Measures
119(2)
4.4 Constraints Imposed by the Scope of Double Tax Agreements (DTAs)
121(25)
4.6 Constraints Imposed by the Membership of the WTO
146(21)
Part II
5 The OECD Secretariat's and Inclusive Framework's Proposals for Multilateral Reforms
167(46)
5.1 Introduction
167(1)
5.2 Pillar One: Allocation of Taxing Rights and Nexus
167(9)
5.3 Pillar One: What Is Proposed in the Unified Approach Proposal? Three Components of Income: Amount A
176(17)
5.4 Amount B: Fixed Remuneration for Marketing and Distribution
193(5)
5.5 Amount C: The "Top-Up"
198(2)
5.6 Dispute Prevention and Resolution
200(4)
5.7 Pillar Two: Global Anti-base Erosion Proposal
204(7)
5.8 Conclusion
211(2)
6 Examining the Proposals for Multilateral Reforms
213(24)
6.1 Does the 2020s Compromise Address the Challenges of the Digital Economy to the International Tax Framework?
213(3)
6.2 Dealing with the Vanishing Ability to Tax Business Profits
216(7)
6.3 The Use of Data, the Contribution of Users and the Measurement of Their Value
223(3)
6.4 The Reliance on, and Mobility of, Intellectual Property
226(1)
6.5 The Characterisation of Transactions and Income
227(1)
6.6 The Failure of Transfer Pricing with Certain Multinational Enterprises and Their Transactions
228(4)
6.7 Tackling the Inadequacy of Residence-Based Taxation
232(1)
6.8 Competition by States
233(2)
6.9 Conclusion
235(2)
7 Implementing the Proposals for Multilateral Reforms
237(26)
7.1 Issues with the Implementation of the 2020s Compromise?
237(14)
7.2 Implementing the Changes Proposed by Amount B
251(2)
7.3 Issues with Implementing Amounts A, B and C
253(1)
7.4 Issues with Implementing Key Elements of Pillar Two
254(6)
7.5 Common Pillar One and Two Implementation Issues
260(3)
8 The Influence of Alternative Policy Strategies on the 2020s Compromise
263(42)
8.1 Where Do the Strategies of the 2020s Compromise Originate?
263(2)
8.2 Destination-Based Cash Flow Taxation
265(7)
8.3 Residual Profit Allocation by Income
272(8)
8.4 Formulary Apportionment
280(5)
8.5 Expanding the Concept of Permanent Establishment
285(20)
9 Interim Solutions and Long-Term Reforms
305(17)
9.1 Crossroads: Responding in a Unilateral or a Unified Way?
305(1)
9.2 Key Generic Design Issues with DSTs
306(7)
9.3 Significant Areas of Change in the 2020s Compromise
313(9)
Index 322
Craig Elliffe is a Professor of Taxation Law at the University of Auckland. Prior to becoming an academic, he spent twenty-three years as a tax partner for major international legal and accounting partnerships. He was the first New Zealander to be appointed to the Permanent Scientific Committee of the International Fiscal Association and a member of the New Zealand government's 2018/2019 Tax Working Group. His book International and Cross-Border Taxation in New Zealand won international plaudits and the JF Northey prize for the best legal book published in New Zealand in 2015.