Value creation; BEPS; digital economy; international taxation; income allocation
Abstract :
[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 :
Tax law European & international law
Author, co-author :
HASLEHNER, Werner ; University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Law Research Unit
Language :
English
Title :
Taxing where value is created in a post-BEPS (digitalized) world?