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The emergence of the "technological tax hub" digitally oriented trajectories of reforms in tax planning hub jurisdictions Nikolai Milogolov

By: Milogolov, Nikolai.
Material type: ArticleArticlePublisher: 2020Subject(s): COMPETENCIA FISCAL NOCIVA | ELUSION FISCAL | FISCALIDAD INTERNACIONAL | ECONOMÍA DIGITAL | TRIBUNAL DE JUSTICIA DE LAS COMUNIDADES EUROPEAS | PAISES BAJOS | SINGAPUR | HONG KONG | MALTA | CHIPRE In: Intertax v. 48, Issue 12, December 2020, p. 1104-1124Summary: This article contains an empirical analysis of the recent tax developments in five major tax planning hub jurisdictions (the Netherlands, Cyprus, Malta, Singapore, and Hong Kong) by testing their potential for attracting the important parts of the value chain (significant people functions, intellectual property (IP), and the digital infrastructure) in the context of the highly digitalized businesses (platforms, cloud computing, fintech, robotics, and artificial intelligence). The digitalized businesses require relatively less physical substance for the creation of significant economic value. The combination of tax incentives for Multinational Enterprises (MNEs) and start-ups, transfer pricing rules, rules for valuation of intellectual property (IP), and wage tax incentives are increasingly used by the ‘tax hub’ countries to win in the global economic battle for the most important parts of the digitalized value chains that exacerbate tax competition.
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Disponible también en formato electrónico.

Resumen.

This article contains an empirical analysis of the recent tax developments in five major tax planning hub jurisdictions (the Netherlands, Cyprus, Malta, Singapore, and Hong Kong) by testing their potential for attracting the important parts of the value chain (significant people functions, intellectual property (IP), and the digital infrastructure) in the context of the highly digitalized businesses (platforms, cloud computing, fintech, robotics, and artificial intelligence). The digitalized businesses require relatively less physical substance for the creation of significant economic value. The combination of tax incentives for Multinational Enterprises (MNEs) and start-ups, transfer pricing rules, rules for valuation of intellectual property (IP), and wage tax incentives are increasingly used by the ‘tax hub’ countries to win in the global economic battle for the most important parts of the digitalized value chains that exacerbate tax competition.

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