Fjord Kjaersgaard, Louise
Blockchain technology and the allocation of taxing rights to payments related to initial coin offerings / Louise Fjord Kjaersgaard .-- , 2020
Resumen.
The author explores one of the most debated technologies of recent times – blockchain technology – from an international tax perspective. The focus is on its main principles in its current stage and how the technology may create value in certain use cases. Being one of the most common use cases benefitting from the main principles of blockchain technology, it is analysed how capital raised through initial coin offerings and the investors’ return on their invested capital should be classified according to the OECD Model Tax Convention 2017. More specifically, emphasis is placed on classification of capital raised through the issuing of utility tokens, debt tokens, and equity tokens as well as the classification of return on investments in such tokens.
BLOCKCHAIN
CRIPTOMONEDA
FISCALIDAD INTERNACIONAL
ELUSION FISCAL
PLANIFICACION FISCAL INTERNACIONAL
MODELO DE CONVENIO OCDE
Intertax 0165-2826v. 48, n. 10 October 2020, p. 879-903
Blockchain technology and the allocation of taxing rights to payments related to initial coin offerings / Louise Fjord Kjaersgaard .-- , 2020
Resumen.
The author explores one of the most debated technologies of recent times – blockchain technology – from an international tax perspective. The focus is on its main principles in its current stage and how the technology may create value in certain use cases. Being one of the most common use cases benefitting from the main principles of blockchain technology, it is analysed how capital raised through initial coin offerings and the investors’ return on their invested capital should be classified according to the OECD Model Tax Convention 2017. More specifically, emphasis is placed on classification of capital raised through the issuing of utility tokens, debt tokens, and equity tokens as well as the classification of return on investments in such tokens.
BLOCKCHAIN
CRIPTOMONEDA
FISCALIDAD INTERNACIONAL
ELUSION FISCAL
PLANIFICACION FISCAL INTERNACIONAL
MODELO DE CONVENIO OCDE
Intertax 0165-2826v. 48, n. 10 October 2020, p. 879-903