000			02010nab a2200253 c 4500
999			_c142413 _d142413
003			ES-MaIEF
005			20221014182053.0
007			ta
008			200824t2020 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
041			_aeng
100	1		_aLipniewicz, Rafal _959850
245		0	_aPlace of effective management in the digital economy _c Rafal Lipniewicz
260			_c2020
500			_aResumen.
520			_aTax residence is one of the essential elements of an international tax regime that is based on a network of tax treaties. In the traditional economy, the identification of the place of tax residence of companies usually does not create interpretative problems. However, the dynamic development of the digital economy raises questions as to whether the concept of the place of effective management (POEM) is also an appropriate instrument for companies. It is used as a tie-breaker rule and national residence test based on the axiom of one location of the place where major decisions are made that affect the functioning of the enterprise as a whole. However, due to the growing importance of data collection, processing, and monetization processes - with the intensive use of advanced algorithms and artificial intelligence - it changes hierarchical, linear management models and implements an approach based on decentralization and dispersion of decision-making processes. The considerations contained in this article also pertain to the issue of the desirability of developing a tax connector other than the POEM from the perspective of examining the nature of the economic relationships of "digital companies" with the state for the purposes of tax law.
650		4	_948454 _aSOCIEDADES
650		4	_96729 _aEMPRESAS
650		4	_948282 _aRESIDENCIA FISCAL
650		7	_966104 _aECONOMÍA DIGITAL
650		4	_aIMPUESTOS _947460
773	0		_9162493 _oOP 2141/2020/6/7 _tIntertax _w(IEF)55619 _x 0165-2826 _gv. 48, Issues 6-7, June / July 2020, p. 602-615
942			_cART