Value creation; BEPS; digital economy; international taxation; income allocation
Résumé :
[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 http://kluwertaxblog.com/2018/05/30/taxing-value-created-post-beps-digitalized-world/
Disciplines :
Droit fiscal Droit européen & international
Auteur, co-auteur :
HASLEHNER, Werner ; University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit
Langue du document :
Anglais
Titre :
Taxing where value is created in a post-BEPS (digitalized) world?