Читать книгу Global Tax Governance. Taxation on Digital Economy, Transfer Pricing and Litigation in Tax Matters (MAPs + ADR) Policies for Global Sustainability. Ongoing U.N. 2030 (SDG) and Addis Ababa Agendas онлайн

11 страница из 100

Let me now try to answer the three questions that I posed at the beginning of this chapter.

Much of the current debate has focused on the negative impacts of digitalization such as challenges to traditional tax concepts. For example, the Permanent Establishment (PE) concept which has for a century been the bedrock of tax treaties determining who is allocated the right to tax under tax treaties. Physical presence over a period time (though “permanency” was never actually required) was taken as a good proxy for a significant economic presence which should be subject to taxation of profits made through that presence.

Over the years the PE concept has been adapted to changing business models, though it has its own uncertainties, differing interpretations and issues of practical application. It has at times been abused to avoid taxation where profits are made, and where citizens and governments expect profits to be taxed as a matter of tax fairness.