Digitalisation Changes the World – But Does it Change the Tax World and How?
The factors that until now have determined how to allocate taxable income among different states are in the process of dissolving. The traditional basis of where the taxed entity had its “permanent establishments” was one of the clearest, most reliable factors. It was something you could see, touch – and tax. But where are the permanent establishments of a website company? Where is the “place of management” if all of the officers of the company are perpetually travelling, holding meetings via Skype from different locations.
What new factors should replace the old ones? Or does should the international allocation of taxable income be reworked from the ground up? Developed countries (which essentially created the old rules) will prefer different factors from emerging economies. The session will analyse this and other impacts of digitalisation on the tax world and consider possible solutions from different perspectives.