The spread of the digital economy poses challenges for international taxation. This report sets out an analysis of these tax challenges. It notes that because the digital economy is increasingly becoming the economy itself, it would not be feasible to ring-fence the digital economy from the rest of the economy for tax purposes. The report notes, however, that certain business models and key features of the digital economy may exacerbate BEPS risks. These BEPS risks will be addressed by the work on the other Actions in the BEPS Action Plan, which will take the relevant features of the digital e
Foreword; Table of contents; Abbreviations and acronyms; Executive summary; Introduction to tax challenges of the digital economy; Bibliography; Fundamental principles of taxation; Overarching principles of tax policy; Taxes on income and consumption; Corporate income tax; Value added taxes and other indirect consumption taxes; Notes; Bibliography; Information and communication technology and its impact on the economy; The evolution of information and communication technology; Emerging and potential future developments
The interactions between various layers of information and communication technology (ICT): a conceptual overviewNote; Bibliography; The digital economy, new business models and key features; The spread of ICT across business sectors: the digital economy; The digital economy and the emergence of new business models; Key features of the digital economy; Notes; Bibliography; Identifying opportunities for BEPS in the digital economy; Common features of tax planning structures raising BEPS concerns; BEPS in the context of direct taxation; Notes; Bibliography; Tackling BEPS in the digital economy
IntroductionRestoring taxation on stateless income; Addressing BEPS issues in the area of consumption taxes; Bibliography; Broader tax challenges raised by the digital economy; The digital economy and the challenges for policy makers; An overview of the tax challenges raised by the digital economy; Nexus and the ability to have a significant presence without being liable to tax; Data and the attribution of value created from the generation of marketable location-relevant data through the use of digital products and services; Characterisation of income derived from new business models
Collection of VAT in the digital economyNotes; Bibliography; Potential options to address the broader tax challenges raised by the digital economy; Introduction; Options proposed to the Task Force; Framework for evaluating potential options; Initial evaluation of potential options; Notes; Bibliography; Conclusions; The digital economy, its business models, and its key features; BEPS issues in the digital economy and how to address them; Broader tax policy challenges raised by the digital economy; Next steps; Bibliography; Annex A. Prior work on the digital economy
Annex B. Typical tax planning structures in integrated business models
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