Double Taxation

Breaking Bad or Breaking Safely

Critique comes cheaply, one may retort, but the current state of affairs is not better. Rogue countries (ironically again, led by the purported leaders of the OECD, such as the United Kingdom and France) were able to capture a share of what they believe they “deserve” in the form of taxation of the large tech MNE in various forms of “new” taxes that are supposedly external to the international tax regime and therefore not viewed as its violation.

Azerbaijani practice of taxing cross-border digital supplies: Needs for Improvement

Technological progress and trade liberalization dramatically increased electronic trade and opened new chapter for the businesses to remotely supply services and intangibles to the customers anywhere around the world. Such rise of e-trade and emergence of global economy created new challenges for the policy makers in applying goods and services tax (GST) on cross-border business to consumer (“B2C”) transactions.

Taxation of Digital Economy in Peru

In the modern world, new questions arise since due to the new technologies, the criteria described before may not be enough to determine if certain operations should be taxed or not in certain jurisdictions. In the following lines we will presenting the situation of digital economy taxation in Peru and where possible, offer solutions where necessary.

Global Digital Taxation in the Era of Covid-19: An African Perspective

African countries would also need to ensure that the nexus-revenue threshold is as low as possible, in order to accommodate jurisdictions with a relatively small market. Other important issues that are still outstanding include i) the definition between routine and residual profits, ii) the required threshold for determining the portion of residual profits allocable, and iii) how the profits would be allocated to market jurisdictions

Departing from the OECD’s Conversation: Post-Pandemic Tax Policy Options for African Countries

In the tax world, this is significant because businesses react to tax policy. Tax policy, in turn, stimulates the interest of both local and international investors who are the key drivers of economic growth. Therefore, the challenges of the economic downturn will be more glaring and significant for African countries, who have a greater reliance on tax revenue from large taxpayers than more advanced economies.

Remedying the Power Imbalance in Negotiations for Bilateral Tax Treaties

Developing countries are currently disadvantaged in the international tax regime. The control of the developed countries in the tax regime is evidenced in their influence in the creation of the major model tax treaties that are used as the starting point for nearly all bilateral tax treaties today. With the rise of multilateral tax instruments and an awareness of the dubious flow of tax revenue out of already disadvantaged countries, developing countries should consider renegotiating their bilateral tax treaties to ensure a more balanced international tax system that is designed for their benefit.