Taxation of outer space income resulting from air transport or employment activities is the OECD Model Convention an appropriate tool? Gaëtan Zeyen
By: Zeyen, Gaëtan
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Material type: 
ArticlePublisher: 2021Subject(s): INDUSTRIA ESPACIAL | RENTA | FISCALIDAD INTERNACIONAL | MODELO DE CONVENIO OCDE
In:
Intertax v. 49, n. 4, April 2021, p. 333-342Summary: Space related activities (resulting for example from space tourism or exploration and exploitation of outer space resources) will likely generate in near future increasing revenue. Currently, the issues of the ‘taxability’ or taxation of such revenue in an international context have not been questioned or examined. It is rather assumed that the current version of the OECD Model Convention constitutes a proper legal tool to apprehend and resolve space related tax issues. The OECD Model Convention, however, relies on some fundamental principles, such as the concepts of residence (requiring a physical presence) or state’ sovereignty, which seem prima facie not very well adapted to resolve space related tax issues. The purpose of the present contribution is therefore to check and verify this simple assumption, at the light of two specific issues: international transport issues and international employment issues.
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|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2021/4-4 (Browse shelf) | Available | OP 2141/2021/4-4 |
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| OP 2141/2021/4-1 The reform of the international tax system | OP 2141/2021/4-2 Trends in EU tax policy | OP 2141/2021/4-3 Blockchain and smart contracts | OP 2141/2021/4-4 Taxation of outer space income resulting from air transport or employment activities | OP 2141/2021/4-5 BEPS Action 2 and the non-discrimination rule under the GATS | OP 2141/2021/4-6 The Gulf Cooperation Council (GCC) states | OP 2141/2021/5 Intertax |
Disponible también en formato electrónico.
Resumen.
Space related activities (resulting for example from space tourism or exploration and exploitation of outer space resources) will likely generate in near future increasing revenue. Currently, the issues of the ‘taxability’ or taxation of such revenue in an international context have not been questioned or examined. It is rather assumed that the current version of the OECD Model Convention constitutes a proper legal tool to apprehend and resolve space related tax issues. The OECD Model Convention, however, relies on some fundamental principles, such as the concepts of residence (requiring a physical presence) or state’ sovereignty, which seem prima facie not very well adapted to resolve space related tax issues. The purpose of the present contribution is therefore to check and verify this simple assumption, at the light of two specific issues: international transport issues and international employment issues.
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