Reference : Taxing where value is created in a post-BEPS (digitalized) world?
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Taxing where value is created in a post-BEPS (digitalized) world?
Haslehner, Werner mailto [University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit >]
Kluwer International Tax Blog (
Weber, Dennis
Mueller, Johann
Rocha, Sergio André
Goel, Shilpa
Kluwer Law International
Aalphen aan den Rijn
The Netherlands
[en] Value creation ; BEPS ; digital economy ; international taxation ; income allocation
[en] As international tax reform aims to ensure "taxation where value is created", it is crucial to ask questions about the relationship between taxation and value creation, in particular with respect to increased digitalisation. As the notions of value creation and substance are inextricably linked to a functional analysis of business activity, further the challenges arising from artificial intelligence taking independent decisional control over key business functions will also need to be considered. This brief note outlines some of the existing developments in the relationship between these factors. The blog is available at
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