Essays about: "digital PE"

Showing result 1 - 5 of 8 essays containing the words digital PE.

  1. 1. Does the Substance over Form approach implemented as a result of the BEPS package reconciles the Permanent Establishment definition with the existence of economic allegiances?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Moisés Zúñiga Vargas; [2019]
    Keywords : Taxes; Permanent Establishment; economic allegiances; MLI; OECD; BEPS; Model Tax Convention; International taxation; Law and Political Science;

    Abstract : The Permanent Establishment (PE) concept plays a key role in the distribution of taxing rights between States by determining when the profits derived by an entity are taxable in a State other than the State of its residency. This concept, originally, evidenced the existence of sufficient economic allegiances between a non-resident entity and a State to justify taxation therein. READ MORE

  2. 2. Rethinking traditional source concepts in a digital economy

    University essay from Uppsala universitet/Juridiska institutionen

    Author : George Daniel Costache; [2019]
    Keywords : International; tax law; OECD; digital economy; BEPS; Action 1; EU law; digital PE; DST; tax law; source taxation;

    Abstract : The purpose of this thesis is to provide meaningful understanding of the current state of business activities, which generates the need for implementing new taxing measures, analyse the challenges arising from this need, as well as their cause. Furthermore, the aforementioned challenges will be explained in the context of existing traditional taxing systems and proposed measures will be analysed. READ MORE

  3. 3. European Commission's proposal to implement a new permanent establishment nexus based on significant digital presence - Is it compliant with the EU Law and international tax principles?

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Lara Nogueira; [2018]
    Keywords : Taxation of the Digital Economy; New permanent establishment nexus based on significant digital presence; Proportionality of the proposal and its compatibility with the Ottawa Principles.; Law and Political Science;

    Abstract : The taxation of the digital economy has become a relevant subject, as business models and value creation chains of all sectors have been transformed bringing challenges to the international tax system and parameters for the allocation of taxing rights between source and residence jurisdictions. In view of these changes, the European Commission has published two proposals for directives on the taxation of digital activities, proposing solutions to be harmonized into the system of direct taxation of Member States. READ MORE

  4. 4. Income taxation at the right place at the right time - An analysis of the need for a virtual permanent establishment

    University essay from Lunds universitet/Juridiska institutionen; Lunds universitet/Juridiska fakulteten

    Author : Johan Brodd; [2018]
    Keywords : skatterätt; tax law; permanent establishment; corporate income taxation; significant digtal presence; significant economic presence; virtual permanent establishment; PE; Virtual PE; Law and Political Science;

    Abstract : In the last couple of years, taxation of the digital economy has become a subject that is on everybody’s mind. This has given rise to attempts from OECD and EU, amongst others, to solve this dilemma. READ MORE

  5. 5. Profit-allocation based on value creation in the digital economy

    University essay from Lunds universitet/Institutionen för handelsrätt

    Author : Tim Theunis; [2018]
    Keywords : Digital economy; value creation; tax; taxation; profit-allocation; permanent establishment; digital permanent establishment; virtual permanent establishment; formulary apportionment; arm s length principle; BEPS Action 1; BEPS Action 7; digitalization; digitalisation; European Commission; Directive; attribution of profits; value drivers; user jurisdiction; data; profit split method; transfer pricing; Law and Political Science;

    Abstract : With the proposed Directive by the European Commission to tax the digital economy more effective by introducing a digital permanent establishment, the question raises how to effectively tax it. Under the current profit-allocation principles, profits are allocated to the jurisdiction in which the significant people functions are situated. READ MORE