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Allocation of the taxing right to payments for cloud computing-as-a-service Louise Fjord Kjaersgaard

By: Fjord Kjaersgaard, Louise.
Material type: ArticleArticlePublisher: 2019Subject(s): INFORMÁTICA EN LA NUBE | SERVICIOS DIGITALES | IMPUESTOS | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICOOnline resources: Click here to access online In: World Tax Journal v. 11, n. 3, October 2019, p. 379-423Summary: The author analyses the options available to user jurisdictions for taxing the value generated by cloud computing service providers. The focus is on the challenges of allocating the taxing right to payments for cloud computing provided as a service in the form of Infrastructure-as-a-Service, Platform-as-a-Service and Software-as-a-Service, deployed as both public and private cloud computing. More specifically, the focus is on mixed contracts, the distinction between business income and royalties and whether the provision of such services constitute a permanent establishment.
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Resumen.

The author analyses the options available to user jurisdictions for taxing the value generated by cloud computing service providers. The focus is on the challenges of allocating the taxing right to payments for cloud computing provided as a service in the form of Infrastructure-as-a-Service, Platform-as-a-Service and Software-as-a-Service, deployed as both public and private cloud computing. More specifically, the focus is on mixed contracts, the distinction between business income and royalties and whether the provision of such services constitute a permanent establishment.

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