This new era,shaped dramatically by technology developments and globalization,requires not just an overhaul of existing tax systems but a radical shift in the international tax perspective overall.As the national legi...This new era,shaped dramatically by technology developments and globalization,requires not just an overhaul of existing tax systems but a radical shift in the international tax perspective overall.As the national legislators and tax authorities struggle to keep pace with the evolving technology,an international and coordinated solution appears pivotal.Coordinated and coherent solutions have been put forward by the OECD and G20 countries with Action Plan(addressing BEPS with 15 actions to be implemented in domestic tax frameworks).As for the challenges arising from digitalization,further headway still needs to be made.Hence,one of the essential tasks of the OECD/G20 Inclusive Framework is to address such tax challenges arising from the digitalization of the global economy.Challenges like these are tackled with the socalled“Two-Pillar Solution”,which aims at ensuring that multinational enterprises pay a fair share of tax wherever they operate and generate profits.On the one hand,the“Two-Pillar Solution”ensures that profits are taxed where economic activities take place and where value is created while,on the other hand,it creates a level playing field for multinational enterprises as regards taxation.It is still though too early in the day to judge whether this Two-Pillar Solution will ultimately reach its goals.However,what is clear is that this solution amounts to a major change in international taxation or as I call it:“A‘Giant Leap’for Multinational Groups”.展开更多
Even though Article 5 is one of the most relevant and long-standing articles of the OECD model,its application often tends to raise issues.This is given by the circumstance that the application of this article heavily...Even though Article 5 is one of the most relevant and long-standing articles of the OECD model,its application often tends to raise issues.This is given by the circumstance that the application of this article heavily depends on the interpretation of both factual and legal circumstances and that there are still several open issues that were never clearly dealt with by the OECD Commentary.Finally,even though the last amendments made to Article 5(especially to the agency permanent establishment rules)seem to be effective in order to counteract some common practices used to avoid giving rise to a permanent establishment,such amendments fall short of tackling the main challenge of our time:the digitalisation of economy.展开更多
文摘This new era,shaped dramatically by technology developments and globalization,requires not just an overhaul of existing tax systems but a radical shift in the international tax perspective overall.As the national legislators and tax authorities struggle to keep pace with the evolving technology,an international and coordinated solution appears pivotal.Coordinated and coherent solutions have been put forward by the OECD and G20 countries with Action Plan(addressing BEPS with 15 actions to be implemented in domestic tax frameworks).As for the challenges arising from digitalization,further headway still needs to be made.Hence,one of the essential tasks of the OECD/G20 Inclusive Framework is to address such tax challenges arising from the digitalization of the global economy.Challenges like these are tackled with the socalled“Two-Pillar Solution”,which aims at ensuring that multinational enterprises pay a fair share of tax wherever they operate and generate profits.On the one hand,the“Two-Pillar Solution”ensures that profits are taxed where economic activities take place and where value is created while,on the other hand,it creates a level playing field for multinational enterprises as regards taxation.It is still though too early in the day to judge whether this Two-Pillar Solution will ultimately reach its goals.However,what is clear is that this solution amounts to a major change in international taxation or as I call it:“A‘Giant Leap’for Multinational Groups”.
文摘Even though Article 5 is one of the most relevant and long-standing articles of the OECD model,its application often tends to raise issues.This is given by the circumstance that the application of this article heavily depends on the interpretation of both factual and legal circumstances and that there are still several open issues that were never clearly dealt with by the OECD Commentary.Finally,even though the last amendments made to Article 5(especially to the agency permanent establishment rules)seem to be effective in order to counteract some common practices used to avoid giving rise to a permanent establishment,such amendments fall short of tackling the main challenge of our time:the digitalisation of economy.
