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This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).
In May 2019, the Inclusive Framework adopted a Programme of Work, which was endorsed by the G20 Finance Ministers and G20 Leaders in June 2019. The Programme of Work outlined proposals in two pillars that could form the basis for a multilateral consensus-based solution. This report presents an ex ante analysis of the economic and tax revenue implications of the Pillar One and Pillar Two proposals under discussion by the Inclusive Framework as part of its work to address the tax challenges arising from the digitalisation of the economy.
This is the fourth edition of Tax Policy Reforms: OECD and Selected Partner Economies, an annual publication that provides comparative information on tax reforms across countries and tracks tax policy developments over time. The report covers the latest tax policy reforms in all OECD countries, as well as in Argentina, Indonesia and South Africa. Monitoring tax policy reforms and understanding the context in which they were undertaken are crucial to informing tax policy discussions and to supporting governments in the assessment and design of tax reforms.
This book has the merit of being the first book analysing different aspects of data taxation from a wide perspective encompassing not only tax law but also other significant issues related to data, such as data protection and economic inefficiencies. The main aim is to provide data-specific solutions to data-driven problems. In the midst of a number of critical issues and a great deal of uncertainty currently reigning in the field, the authors attempt to put forward easy-to-implement and efficient proposals on the basis of an interdisciplinary analysis. The core idea of this book consists of segregating the utilisation of data into four different yet interdependent steps and constructing the tax law analysis on top of these four corner stones. Step one, occurring in the generation and collection phases of the data’s life cycle, comprises ‘the digital barter’ and other collection of data. Step two, taking place during the processing and analytics phases of the data’s life cycle, consists of microwork. Step three, situated in the storage, processing, analytics and use phases of the data’s life cycle, encompasses aggregation and internal use of data. Step four, materialising during the distribution and use phases of the data’s life cycle, covers sale of data, transfer of data and granting the right to use a database. The main issues occurring in each of the four steps are analysed separately, and yet interdependently, with an emphasis on international tax law. The book also comprises a VAT analysis; suggestion of a new type of tax, namely «data collection tax»; and a brief opinion on a potential future «robo-data tax». The subjects explored in this book are of interest for researchers, lawyers as well as tax administrations. Albeit being an academic publication, the developments made in this contribution are also relevant for the general public. After all, data, the youngest intangible, constitute the raw material of the fourth industrial revolution; and their use and taxation affect each and every citizen!
An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repercussions on all aspects of taxation - direct taxation, indirect taxation, and even tax procedures. For instance, the quest for more justice and equality in profit taxes was the reason why, in October 2021, a historical deal based on a two-pillar solution to address the tax challenges arising from the digitalization of the economy was negotiated within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and agreed upon by 137 member countries. It was also the motive behind the shift from a typical vendor collection model to an intermediary collection model supported by centralized registration points in indirect taxes, notably the VAT/GST. Abundant data from the European Union or the OECD signalized an ever-increasing gap between expected VAT revenues and VAT actually collected, making it obvious that the classical system of VAT/GST collection was unable to respond to challenges posed by the digital economy. Therefore, new solutions based on the participation of digital platforms as intermediaries had been introduced. Finally, new technologies, such as blockchain, paved new avenues in enhancing tax compliance. In this context, this volume entitled "Justice, Equality, and Tax Law" contains not only a selection of the best master ́s theses of the full-time LL.M. programme in 2021/2022 but also represents an in-depth analysis of various aspects of this evergreen topic.
Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.
This report contains detailed profiles of twelve of the world’s leading platform companies and derives insights from those profiles about what platforms actually do, how they do it, and why they succeed financially.
This book presents an analysis of the challenges the spread of the digital economy poses for international taxation.