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TPI 4, August 2023, Seite 137

Taxation of the Digital Economy

What Is All the Discussion About? Value Creation?

Mirna S. Screpante

Taxation of the digital economy pertains to the challenges and complexities surrounding the taxation of economic activities that occur in the digital realm. The key issues revolve around identifying the appropriate tax base, allocating profits among countries, addressing digital presence and value creation, and preventing tax avoidance and profit shifting. It requires adapting traditional tax frameworks to accommodate the unique characteristics and global nature of the digital economy. However, this task does not seem to be easy to achieve.

1. Introductory Remarks

The development of the digital economy has posed issues for international taxation in the last years. Multinational corporations normally pay corporate income tax in the jurisdiction where they have a physical presence, not in the location of consumers or, more precisely, users in the digital sector. Some argue that, due to the lack of a physical presence, businesses that (implicitly) earn income from consumers in other nations via the digital economy are not subject to corporate income tax in those countries.

Taxation of the digital economy has numerous consequences: the ability of a company to have a significant digital pr...

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