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

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Digitalization also challenges the Arm’s Length Pricing (ALP) approach in transfer pricing – the potentially manipulated pricing of internal MNE transactions. This approach is based upon the idea that you can allocate the profits of an MNE on the basis of the separate entity concept, that each component is a separate legal entity. Some commentators believe that the ALP can be adapted to today digital environment, (me included) while still retaining the inherent good sense of looking at market pricing; others consider that we need to move to a Global Formulary Approach. This is at the center of Pillar 1 of the BEPS 2.0 digital taxation debate.

These challenges are not limited to the CIT. They also apply to:

o VAT although we seem more successful in adapting our VAT rules than our CIT rules, and implementing a destination approach that recognizes the importance of markets to value creation, and that consumption is a less mobile factor than capital.

o And there are also challenges to the way we tax individuals, particularly the HNWI, who have greater freedom in where to carry out their digital activities. This has led countries to put in place special regimes to attract such people.