Taxing the digital economy a case study on the Unified Approach Stefan Greil & Thomas Eisgruber
By: Greil, Stefan
.
Contributor(s): Eisgruber, Thomas.
Material type: 
ArticlePublisher: 2021Subject(s): ECONOMÍA DIGITAL | IMPUESTOS | PRIMER PILAR (OCDE) | ENFOQUE UNIFICADO (OCDE) | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO
In:
Intertax v. 49, n. 1, January 2021, p. 53-70Summary: In October 2020, the OECD Secretariat published the ‘Report on Pillar One Blueprint’ approved by the Inclusive Framework on BEPS as a result of the work on the tax challenges arising from digitization. This contribution attempts to explain the application of the Unified Approach, especially Amount A using a case study. The case study reveals a considerable complexity of the proposed new system. Therefore a simplification potential is to be pointed out at the same time, in order to make Amount A practicable. The possibility is not precluded that certain aspects could be interpreted or regarded differently. Therefore, this case study intends to contribute to the development of a common understanding, too. It is important that all participants in a multilateral system have a common understanding. Otherwise, this results in double taxation and enormous administrative challenges for taxpayers and tax administrations. There is still the opportunity to make changes. This should be used now, since multilateral systems are difficult to change once they have been implemented. Finally, the application of the proposed draft of the new Article 12B of the UN Tax Treaty Model is also considered.
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| Artículos | IEF | IEF | OP 2141/2021/1-6 (Browse shelf) | Available | OP 2141/2021/1-6 |
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Resumen.
In October 2020, the OECD Secretariat published the ‘Report on Pillar One Blueprint’ approved by the Inclusive Framework on BEPS as a result of the work on the tax challenges arising from digitization. This contribution attempts to explain the application of the Unified Approach, especially Amount A using a case study. The case study reveals a considerable complexity of the proposed new system. Therefore a simplification potential is to be pointed out at the same time, in order to make Amount A practicable. The possibility is not precluded that certain aspects could be interpreted or regarded differently. Therefore, this case study intends to contribute to the development of a common understanding, too. It is important that all participants in a multilateral system have a common understanding. Otherwise, this results in double taxation and enormous administrative challenges for taxpayers and tax administrations. There is still the opportunity to make changes. This should be used now, since multilateral systems are difficult to change once they have been implemented. Finally, the application of the proposed draft of the new Article 12B of the UN Tax Treaty Model is also considered.
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