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Taxation and Value Creation
Haslehner, Werner; Lamensch, Marie
2021IBFD, Amsterdam, Netherlands


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Keywords :
Value Creation; Tax policy; International tax reform; OECD BEPS Project; Economics of taxation
Abstract :
[en] The suggestion to “align international taxation with value creation” first emerged in the context of the OECD BEPS Project aimed at tackling aggressive tax planning strategies resulting in base erosion and profit shifting. The concept of “value creation” was then further relied on in the broader discussion that followed about the impact of digitalization on the global economy generally and the fair allocation of taxes between countries in this new environment. Although the idea – or the guiding principle – that profits should be taxed where economic activities occur and where value is expected to be created initially received a relatively large support, it rapidly became clear (at least to academics) that there would be no obvious answer to the question “where is value being created?” in a manner that would be relevant for (international) tax purposes, inter alia in view of the different models of value creation within corporate entities. Based on 9 thematic reports (offering an interdisciplinary discussion of the concept of value creation mostly from an international perspective) and on 23 national reports (focusing on the meaning of value creation in domestic tax law), this book seeks to contribute to the discussion on whether the concept of value creation is viable, both theoretically and in practice, as a criterion for the allocation of taxing rights under a modernized international tax framework.
Disciplines :
Tax law
Editor :
Haslehner, Werner  ;  University of Luxembourg > Faculty of Law, Economics and Finance (FDEF) > Department of Law (DL)
Lamensch, Marie
External co-authors :
Language :
Title :
Taxation and Value Creation
Publication date :
April 2021
Publisher :
IBFD, Amsterdam, Netherlands
Number of pages :
Collection name :
EATLP International Tax Series Vol. 19
Focus Area :
Law / European Law
FnR Project :
FNR14493764 - Digitalization, Taxation, And Value Creation, 2020 (20/01/2020-02/06/2020) - Werner Haslehner
Available on ORBilu :
since 19 April 2021


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