Taxing digital activities – comparing the UK, EU and OECD proposals
The current international tax framework maps the taxation of profits to the location of management of key functions, assets and risks. In essence, it seeks to tax profits where value is created. A taxable presence will typically only arise in jurisdictions where an enterprise has a physical establishment.
However, digital business models often enable enterprises to generate revenues within a jurisdiction without significant physical presence. Therefore, many territories consider that value is being created within their borders in the course of provision of digital services, but the current international tax framework does not provide them with a mechanism to tax such profits. It is this perceived gap that the recent papers on the taxation of digital activities from the UK, EU and OECD seek to address.