► Digital economy is raising complex issues for VAT systems
► OECD (November 2015): “International VAT/GST Guidelines” published with a heavy
focus on the place of supply of cross-border supplies of services and intangibles and the
application of the principles of destination and neutrality
► Trend toward digital supplies becoming taxable in the country of consumption
► Businesses increasingly needing to make VAT decisions in real time (at the point
of sale)
► Policymaking is developing – typical developments:
► Joint and several liability for online marketplaces
► Active searches for non-established ESS suppliers
► Removal of low value import thresholds
► Tax authorities are going digital
► Plus increasing inter-governmental cooperation
► Reputational risk rising
The presentation addresses the impact of the digital tax proposal (EU and Italian) on Chinese companies doing business in Italy. It has been used during a seminar at the Chinese University of Fiance and Economics.
FinTech: The revolution is here!
In this session, we will introduce fintech and discuss the eight key innovations in fintech that are revolutionizing how companies are doing business. This session is geared towards fintech enthusiasts and financial industry professionals who are intrigued and fascinated by the innovations in fintech and would like to learn and adapt to the new realities of the 21st century
This PPT is mainly on the basics of International Taxation which is confusing for many students and many professionals too nowadays. During this evolving world of multinational culture, International Taxation has gained significant importance of which all the professionals should be aware of.
I have tried to compile the concepts of international taxation in this PPT except the concept of Transfer Pricing which in itself is like a whole book.
I have inserted the core concepts which lead to the emergence of International Taxation in India.
The presentation addresses the impact of the digital tax proposal (EU and Italian) on Chinese companies doing business in Italy. It has been used during a seminar at the Chinese University of Fiance and Economics.
FinTech: The revolution is here!
In this session, we will introduce fintech and discuss the eight key innovations in fintech that are revolutionizing how companies are doing business. This session is geared towards fintech enthusiasts and financial industry professionals who are intrigued and fascinated by the innovations in fintech and would like to learn and adapt to the new realities of the 21st century
This PPT is mainly on the basics of International Taxation which is confusing for many students and many professionals too nowadays. During this evolving world of multinational culture, International Taxation has gained significant importance of which all the professionals should be aware of.
I have tried to compile the concepts of international taxation in this PPT except the concept of Transfer Pricing which in itself is like a whole book.
I have inserted the core concepts which lead to the emergence of International Taxation in India.
Role of Financial Technology in Banking. This ppt describes the impact of Fintech in Banking and the new technologies that are disrupting the banking and financial services. This also includes the need for innovation in the banking sector. Fintech i.e. Financial technology plays an important role in the banking sector. Retail banking, financial technology, Fintech, innovations, Technologies, Imoact of Fintech in banking.
Financial Acumen for Non Finance professionalsCA Harsh Surana
At Brianna Knowledge Resources, we are trying to get highly innovative in getting your people from a Non Finance back ground, sharpen their financial skills and ' think money' in all their dealing! To know more, write back to me & and I shall help you understand how !
Fintech and Transformation of the Financial Services IndustryRobin Teigland
Slides from our FinTech day as part of the Entrepreneurship & Innovation Concentration in the Stockholm School of Economics Exec MBA program in Stockholm, Sweden.
Presentation by Ian Ball, chief executive officer of the International Federation of Accountants, at the L'Institut des Réviseurs d'Entreprises’ European Study Day conference in Brussels, Belgium, which details the societal role of the audit, the need for adoption of accrual-based accounting by governments and public sector institutions, and IFAC’s commitment to global convergence of international standards.
Tax haven is creating a lot of scope for money laundering and tax evasion. Money Laundering is treated as a crime whereas tax evasion is not treated as crime and there is no strict legal action. Tax haven affects in lower tax collection by countries. The money which should be spent on people is enjoyed by certain group of people.
financial accounting theory by Craig Degan 3rd edition chapter 2
prepared by: Dewan Mahbood Hossain
Assistant Professor, dept. of A.I.S
UNIVERSITY OF DHAKA
Is RegTech the new FinTech? With an increase in regulatory compliance, innovation in technology has become increasingly prevalent throughout the professional and financial services. With the birth of RegTech, we ask, what is it, and how can it be effectively utilised by firms across sectors?
Session by Raffaele Russo, Head, BEPS Project, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
The Easiest way to understand International taxation , Concept of Double taxation and its avoidance agreements (DTAA) and its types . Tax implication of activities of foreign enterprise in India: Mode of entry and taxation respectively.
The digitalization of the global economy has amplified the problem of tax avoidance and tax fairness and led to a rise in digital taxes around the world. This webinar seeks to discuss ways for East Africa to address two crucial issues:
Linking taxation rights to where value is created
Reforming the current corporate income tax system to disincentivize transfer pricing to the jurisdiction with the lowest tax rate.
Role of Financial Technology in Banking. This ppt describes the impact of Fintech in Banking and the new technologies that are disrupting the banking and financial services. This also includes the need for innovation in the banking sector. Fintech i.e. Financial technology plays an important role in the banking sector. Retail banking, financial technology, Fintech, innovations, Technologies, Imoact of Fintech in banking.
Financial Acumen for Non Finance professionalsCA Harsh Surana
At Brianna Knowledge Resources, we are trying to get highly innovative in getting your people from a Non Finance back ground, sharpen their financial skills and ' think money' in all their dealing! To know more, write back to me & and I shall help you understand how !
Fintech and Transformation of the Financial Services IndustryRobin Teigland
Slides from our FinTech day as part of the Entrepreneurship & Innovation Concentration in the Stockholm School of Economics Exec MBA program in Stockholm, Sweden.
Presentation by Ian Ball, chief executive officer of the International Federation of Accountants, at the L'Institut des Réviseurs d'Entreprises’ European Study Day conference in Brussels, Belgium, which details the societal role of the audit, the need for adoption of accrual-based accounting by governments and public sector institutions, and IFAC’s commitment to global convergence of international standards.
Tax haven is creating a lot of scope for money laundering and tax evasion. Money Laundering is treated as a crime whereas tax evasion is not treated as crime and there is no strict legal action. Tax haven affects in lower tax collection by countries. The money which should be spent on people is enjoyed by certain group of people.
financial accounting theory by Craig Degan 3rd edition chapter 2
prepared by: Dewan Mahbood Hossain
Assistant Professor, dept. of A.I.S
UNIVERSITY OF DHAKA
Is RegTech the new FinTech? With an increase in regulatory compliance, innovation in technology has become increasingly prevalent throughout the professional and financial services. With the birth of RegTech, we ask, what is it, and how can it be effectively utilised by firms across sectors?
Session by Raffaele Russo, Head, BEPS Project, OECD Centre for Tax Policy and Administration, Meeting of the OECD Parliamentary Group on Tax, 19 Oct 2015
The Easiest way to understand International taxation , Concept of Double taxation and its avoidance agreements (DTAA) and its types . Tax implication of activities of foreign enterprise in India: Mode of entry and taxation respectively.
The digitalization of the global economy has amplified the problem of tax avoidance and tax fairness and led to a rise in digital taxes around the world. This webinar seeks to discuss ways for East Africa to address two crucial issues:
Linking taxation rights to where value is created
Reforming the current corporate income tax system to disincentivize transfer pricing to the jurisdiction with the lowest tax rate.
With a number of recent and upcoming developments in the OECD's international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy, in view of the upcoming G20 Finance Ministers meeting.
Website: http://oe.cd/taxtalks
In this era of technology intertwined lifestyle, e-commerce has become a way of life. E-commerce seemingly facilitates every other aspect of our lives at a click of a button,
The OECD's new work program would fundamentally change the way multinationals are taxed in the digital age, raising numerous questions of economic effects, compliance costs, and coordination between countries.
The four elements necessary for the OECD to be successful:
1.Identification of the scope and magnitude of the issues being addressed and how they are left unresolved by previous BEPS efforts.
2.A clear set of recommendations on both taxing rights and anti-base erosion policies that do the least amount of harm to economic growth.
3.Economic assessment of the potential impact of the policies on cross-border investment, cost of capital, foreign direct investment, compliance and administration costs, and countries’ tax revenue.
4.Commitment from countries to remove policies that conflict with the recommendations
Over the years, tax competition has led some countries to adopt more neutral, pro-growth business tax policies. This project could directly undermine that progress.
The first of Future Agenda’s ‘World in 2030’ foresights addresses the emerging shift in how multinational digital companies may be taxed in the future so that they make a more balanced contribution to society. In a world increasingly aware of the asymmetric power and influence of organisations that don’t comply to norms and regulations created in the 19th and 20th centuries, it explores three different avenues that could have global impact: the adoption of digital revenue taxes such as those being introduced in Europe; a more sophisticated ‘wealth’ tax on the value of the data an organisation owns, manages, stores or uses; and the idea of a data dividend where all citizens receive a payment for the use of their data as part of a company’s social licence to operate.
Each are being proposed and gaining support with multiple governments globally - and so should be on the radar of any data-rich organisation.
Drawn from multiple expert discussions around the world, this foresight is one of 50 looking at the key issues for the next decade that are being shared throughout 2020.
For more details see https://www.futureagenda.org/the-world-in-2030/
Digitalisation has a wide range of implications for taxation, impacting tax policy and tax administration at both the domestic and international level. As a result, the tax policy implications of digitalisation have been at the centre of the recent global debate over whether or not international tax rules continue to be fit for purpose in an increasingly changing environment.
Equalisation Levy - Newly introduced - scope and nuances finalTilak Agarwal
A webinar on Scope and Nuances of newly introduced Equalisation Levy was presented to the members of Bangalore branch of ICAI. This presentation summarizes some of the relevant considerations and case studies along with issues unresolved on new EQ Levy on e-commerce business. Also covers the Interplay between EQ Levy and TDS u/s 194-O
Key Takeaways:
- Background of BEPS Conflict
- Recommendations and Measures in place
- Significance and impact of G7 Policy Decision
- Way forward on implementation
Presentation from the International Taxation session at the ICTD 7th annual meeting. The panel featured a discussion with Sol Picciotto, Alex Ezenagu, Michael Durst, Catherine Ngina Mutava, Martin Hearson, and Annet Oguttu.
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
Scrambling for New Taxable Bases - Global Digital Economy and Local Fiscal Me...University of Ferrara
This is the presentation used during the Conference held (virtually) at the University of Sevilla "Pablo de Olavide" on December 3rd 2020. It0s a summary of previous input statement with some minor updates as the COVID-19 situation is evolving. The event has been sponsored by the Junta de Andalucía and the European Union in the framework of a research project I am partner of, sponsored by the Spanish ministry of Education.
With a number of recent and upcoming developments in the OECD’s international tax work, we invite you to join a live webcast with experts from the Centre for Tax Policy and Administration for an update on the work relating to the tax challenges arising from the digitalisation of the economy.
Website: http://oe.cd/taxtalks
Taxes are the main source of income for governments as well as a powerful political tool worldwide. Globalization however has progressively opened the business transaction flows, regardless of borders or state lines. As such taxation on international corporations has become increasingly complex to regulate. The G20 will have to weigh the advantages and problems caused by corporations which seek banking abroad in order to avoid taxation. Written by Milain Fayulu and Helen Combes
ECCS Executive Certificate in Cyber Security 4.0Ziaullah Mirza
The development of technologies always has impacts, in positive or negative ways, on businesses, cultures, economies and even on countries. Information Technology is one of the most effective tools with rapid development characteristics for itself as well as businesses around the globe. Cyber Security is one of the best branch or modern tools of Information Technology with respect to security concerns and risk management factors. Information technology is highly integrated into our everyday lives. As a society, we have gone digital. We play, learn, socialize, communicate, and do business online. While cyberspace brings significant benefits, our ever-increasing reliance on it, causing or creating new and significant vulnerabilities.
Voice of Green Hat, brought an innovative research-based certificate in cyber security along with a number of other cutting-edge technological certifications. This research-based certificate is called ECCS. Executive certificate in Cyber Security (ECCS) provides a number of researches in special innovative skills, highly brainstorming strategy to tackle the problems and multidimensional techniques to countermeasure the cyber- attacks and hacking in the cyber space. Not only this, ECCS also covers intermediate skills for digital forensic investigation, risk management and competitive intelligence to understand the attacker’s approaches as well as having deep understanding with today’s Cyber War scenario. This certificate contains six modules of Cyber security & Law; Ethical Hacking & Countermeasure; Digital Forensic Investigation; Competitive Intelligence; Research & Development and Important Demanded Skills
SPECIALIZATION:
• Digital Transformation
• Web & Apps Penetration Testing
• Competitive Intelligence
• Digital Forensic Intelligence
• Digital Economy Vs 5th Gen War Cyber warfare
• Disease-X Alert, Monitoring & Countermeasure
• Industrial Revolution & Hands on Applications for IR4.0
• Implementation of AR, VR, XR and Holo-Lenses
• Flying & Traditional Robotics
• Mind Computing & Research
• Financial Technologies
ابدأ # عملك في # باكستان
معظم # التصنيع الاقتصادي # / # شبكة التوزيع / التسويق
الوصول إلى 1813 #Million Customer #Market
#باكستان
#الصين
#تركيا# و# أذربيجان
#أفغانستان# و # أوزبكستان
#تركمانستان# و طاجيكستان
#الشرق الأوسط
سجل شركة في غضون 3 أيام وابدأ في الاستفادة من الطريق والقطار والطيران والسفن
المجالات الرئيسية للأعمال والاستثمار هي:
# التجارة العامة # التصدير# التعليم_التدريب# الاستثمار_التمويل # العقارات للبناء # التصنيع# التوزيع# الاستشارات# الخدمة# المعلومات# تكنولوجيا# السفر# السياحة
Innovation
Commandment
solutions
providing under
“Green Hats
Technologies,
Voice of Green
Hats & Poiema
Solutions
Pakistan”
Green Economy Transformation
Artificial, Business & Competitive
Intelligence
Industry 4.0
Digital Transformation & Economies
Economic Reforms (Empowerment)
A. Economic Enhancement, Advancement & Empowerment Tools
B. Economic Monitoring & Countermeasures
C. Digital Economy
D. Economic Trending (#Halal, #Kosher, #Halal-Vegetarian, #Kosher-Vegetarian etc.,)
E. Economic Prosperity Factors & Agreements [ integrated economy]
F. Future Economy & Strategies
G. Peace & Harmony (Interfaith, Ahli Kitab [Judaism, Christianity, Islam] Religious Harmony, IntraFaith)
H. Women Empowerment (Tech, Business, High Skills) – Global Empowerment Program
Economy Recovery Ahead!
3. Social Research for Improvement (Welfare & Prosperity)
4. Technological Transformation (Disruptive Technologies and Application)
5. Take Action On Issues (Girls & Women, Health. Education, Finance & Innovation, Food & Hunger, Water & Sanitation, Environment, Citizenship)
6. Decision Making (Using all above factors)
Intelligence in Businesses
Competitiveness & Artificial Methods
Frequently Asked Questions on Anti-Money LaunderingZiaullah Mirza
Frequently Asked Questions on
Anti-Money Laundering,
Countering Financing of Terrorism and Targeted Financial Sanctions for
Designated Non-Financial Businesses and Professions & Non-Bank Financial Institutions
Guidance on Beneficial Ownership
Anti-Money Laundering,
Countering Financing of Terrorism and Targeted Financial Sanctions for
Financial Institutions,
Designated Non-Financial Businesses and Professions and Non-Bank Financial Institutions
Guidance on Verification of Individual Customers for Customer Due Diligence
Anti-Money Laundering, Countering Financing of Terrorism and Targeted Financial Sanctions for Financial Institutions
12 part framework to structure safety assessment for autonomous drivingZiaullah Mirza
NHTSA: National Highway Traffic Safety Administration
An agency of the Executive Branch of the U.S. government who has developed a 12-part framework to structure safety assessment for autonomous driving.
Workfare versus Welfare: Incentive Arguments for Work Requirements in Poverty...Ziaullah Mirza
Workfare versus Welfare: Incentive Arguments for Work
Requirements in Poverty - Alleviation Programs
American Economic Association
BESLEYANDC OATE:W ORKFARVES . WELFARE
THE AMERICAN ECONOMIC REVIEW
Social welfare and the rate structure a new look at progressiveZiaullah Mirza
Social Welfare and the Rate Structure: A New Look at Progressive Taxation
Joseph Bankman and Thomas Griffith, Social Welfare and the Rate Structure: A New Look at Progressive Taxation, 75 California Law Review 1905-1968 (December 1987).
Improving the Measurement of Poverty
By
Rebecca M. Blank
Mark H. Greenberg
1. Introduction
2. The Problem: An Out-of-Date Measure of Poverty
3
. An Improved Measure, Based on the Recommendations of the NAS Panel
4. Making Specific Choices for the New Poverty Measure
5. Recommendations Regarding How to Implement the Approach
6. An Example of What This Might Mean for the Poverty Rate
7. Conclusion
Appendix: Detailed Calculations for the Recommended New Poverty Measure
References
The index, which ranks 180 countries and territories by their perceived levels of public sector corruption according to experts and businesspeople, uses a scale of 0 to 100, where 0 is highly corrupt and 100 is very clean. More than two-thirds of countries score below 50 on this year’s CPI, with an average score of just 43.
It reveals that the continued failure of most countries to significantly control corruption is contributing to a crisis in democracy around the world. While there are exceptions, the data shows that despite some progress, most countries are failing to make serious inroads against corruption.
Transparency International e.V. is an international non-governmental organization which is based in Berlin, Germany, and was founded in 1993. Its nonprofit purpose is to take action to combat global corruption with civil societal anti-corruption measures and to prevent criminal activities arising from corruption
High commodity dependence and structural barriers hindering long-term growth prospects of many developing countries
Intensifying trade tensions between the major economies poses a significant risk to the global
growth outlook
Recent financial market turbulence exposes vulnerabilities in several developing economies
IEDC Advisory Committee Handbook
Welcome to an IEDC Advisory Committee. We are glad you are here and would like to thank you for volunteering your time to support the work of IEDC and its mission to champion the economic development profession. IEDC values your commitment and the economic development community relies on your expertise and engagement in this important committee work.
We hope that you will gain from the experience as much as you contribute to it. The Advisory Committees are an excellent place to network with your peers, engage with the challenges of strengthening our shared profession, and learn about trends and topics that will impact the work that we do.
We have developed this Handbook to help orient you to the role of Advisory Committees in IEDC’s work and explain what the committees do. The Handbook also outlines the policies and procedures that govern IEDC Advisory Committees.
Talk on CP-TPP Comprehensive and Progressive Agreement for Trans-Pacific Part...Ziaullah Mirza
CP-TPP Comprehensive and Progressive Agreement for Trans-Pacific Partnership
The CPTPP was signed by all 11 participating countries - Australia, Brunei Darussalam, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore and Viet Nam - on 8 March 2018 in Santiago, Chile. Signing is an indication that the 11 countries accept the outcome of the negotiations and will start their domestic process to enable their ratification of the Agreement in order to bring the Agreement into force
CANADA - JAPAN ECONOMIC PARTNERSHIP AGREEMENTZiaullah Mirza
Report of the Joint Study on the Possibility of a Canada-Japan Economic Partnership Agreement
http://www.international.gc.ca/trade-agreements-accords-commerciaux/agr-acc/japan-japon/study-report_rapport-etude.aspx?lang=eng
#CanadaMalaysia #MalaysiaCanada #IloveCanadaInMalaysia #IloveCanadaInASEAN #IloveCanadaInAsia
In 2012, Canada and Japan launched negotiations towards an Economic Partnership Agreement (EPA).
The Canadian Agri
-
food Trade Alliance (CAFTA) supports the Canadian government’s efforts to expand
trade and economic ties with Japan. However, to be successful, the Canada
-
Japan EPA must include a
solid agriculture package
Canada - Australia Trade and Economic Cooperation Arrangement (TECA)Ziaullah Mirza
Trade and Economic Cooperation Arrangement Between
the Government of Canada and the Government of
Australia
Acknowledging
the mutual benefits that result from long
-
term a
nd stable economic relations
and the further development of their trade and investment relations;
Reaffirming
, their shared strong commitment to an effective Agreement Establishing the
World Trade Organization, based on clear and mutually advantageous rule
s governing
multilateral trade;
Recognizing
their respective rights and obligations under the Agreement Establishing the
World Trade Organization and other multilateral and bilateral
instruments of
cooperation;
Noting
the importance they attach to the furt
her development of the role of the Asia Pacific
Economic Cooperation (APEC) in the context of closer economic cooperation in the
Asia/Pacific region, particularly the common goals expressed in the Bogor Declaration;
Convinced
that the establishment of a fr
amework for consultations between them on trade
and investment will contribute to the growth of trade and investment between the two
countries;
Canada & Australia - Perfect partners for trade & investmentZiaullah Mirza
With similar federal government institutions, a common legal
heritage, an abundance of natural resources, wealthy
populations and open markets, Canada and Australia have
so much in common.
Such physical, constitutional and commercial
similarities have helped to create strong bilateral
investment ties between the two countries
and strong services exchange.
This presentation poster infographic delves into the multifaceted impacts of globalization through the lens of Nike, a prominent global brand. It explores how globalization has reshaped Nike's supply chain, marketing strategies, and cultural influence worldwide, examining both the benefits and challenges associated with its global expansion.
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Cotton in Nike Apparel
Nike Shops Worldwide
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Cold Cement Assembly Nike
3D Printing Nike Shoes
Nike Product Development
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Nike Distribution Centers
Automation in Nike Manufacturing
Nike Consumer Direct Acceleration
Nike Logistics and Transport
1. Elemental Economics - Introduction to mining.pdfNeal Brewster
After this first you should: Understand the nature of mining; have an awareness of the industry’s boundaries, corporate structure and size; appreciation the complex motivations and objectives of the industries’ various participants; know how mineral reserves are defined and estimated, and how they evolve over time.
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
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1. Taxation of the
digitalized economy
Recent developments
worldwide: is there a
consensus on what to do?
Kuala Lumpur, Malaysia
12 September 2018
2. 2 | Taxation of the digitalized economy
Today’s agenda
How did we get here and what is the current state?
What to expect next
1
2
3. 3 | Taxation of the digitalized economy
Digital tax effectiveness
Managing interconnected themes
Emerging production and consumer
models, as well as new technologies
– all enabled by the proliferation of
the connected economy – are
affecting all companies in every
industry.
Digital breaks down barriers to entry
and growth, enabling companies
instantly to access and monetize
global consumers, reshaping markets
and supply chains, and creating new
business opportunities and risks.
These tax implications offer new
opportunities as well as risk.
Any digital transformation
invariably has multiple tax
implications.
Governments are demanding greater
transparency and introducing new
rules and regulations for the digital
economy. Others are adapting
existing tax and legal concepts for the
new world – creating further
uncertainty.
Industries are blurring and integrating
elements of the technology sector into
aspects of legacy business processes
at an accelerating rate. Existing
enterprises now risk disruption from all
sides. New, forward-looking alliances
are also changing the landscape.
Significant
global shift
in digital
policy
Converging
industries
The digital
revolution
Instant
globalization
Digital tax
effectiveness
4. How did we get here, and
what is the current state?
39784962
5. 5 | Taxation of the digitalized economy
Three issues at the heart of the digital debate
Scale without mass
The ability to have a significant
economic presence in a
country without a major
physical presence.
Reliance on
intellectual property
Particularly heavy reliance on
intangible assets, including
intellectual property.
User
participation and
the value of data
Many evolving business models include
elements of data, user participation,
user-generated content and
network effects.
6. 6 | Taxation of the digitalized economy
Taxation of digitalized activity
A condensed history …
► European Commission
► We don’t agree that the digital economy cannot be ring-fenced
► October 2017: Four Member States (France, Germany, Italy and Spain) call on the EU to
introduce measures
► October 2017: Presidency paper “Unfortunately, it has so far proved difficult to agree on the
solutions at global level, as is evident from the OECD report in October 2015. The time to act
has now come.”
► 21 March 2018: Proposals issued
► 28-29 April – ECOFIN meeting, Bulgaria
► OECD BEPS project
► 2015: “No such a thing as a separate digital economy, but that
companies are now participating in the digitalized economy”
► Addressed via BEPS actions 5, 7, 8-10, plus VAT
► Interim report was bought forward to 16 March 2018
► “A significant number of multinational enterprises (MNEs) have
taken proactive measures to realign their tax arrangements with
their real economic activity”
► No consensus on interim measures
► Outlines framework of design considerations
7. 7 | Taxation of the digitalized economy
The digital tax debate: a timeline of key events
1
2
3
6
5
March 2017:
OECD report to G20
Finance Ministers
identifies digital as one of
three key areas
September 2017:
EU Finance Ministers meeting in
Tallinn, Estonia, covering
corporate taxation challenges of
the digital economy
September 2017:
European Commission
publishes communication to the
European Parliament and
Council confirming direction
November 2017:
OECD holds a public
meeting in San
Francisco
December 2017:
EU Finance Ministers call for the
European Commission to
present its options in early 2018
for EU action
March 2018:
European
Commission
publishes its digital
tax proposals
4
11 12 13 14 15 16 17
1998
OECD report: Electronic
Commerce Taxation
Framework Conditions
2015
OECD final report on
Action 1 published
2018
European Commission
publishes proposals
2018
OECD publishes
interim report
2019
OECD to
publish update to G20
2020
EU Member States to apply
provisions by 1 January
2020
OECD to publish
final report to
G20
Overview2017–2018
8. 8 | Taxation of the digitalized economy
2 4
1 3
The OECD’s interim report
Issued on 16 March 2018
Provides analysis of the main
features frequently observed
in certain highly digitalized
business models and value
creation in the digitalized age.
Describes the complexities of
the issues involved, and the
positions that different
countries have in regard to
these features.
[BEPS IF] Members
agreed to undertake a
coherent and
concurrent review of
the “nexus” and “profit
allocation” rules.
5
Members will work
toward a
consensus-based
solution, noting that
divergent views
exist.
Notes that “There is no consensus on the need for, or merits of, interim measures, with a number of countries
opposed to such measures on the basis that they will give rise to risks and adverse consequences.”
What didn’t we get? 1). Consensus 2). Specific recommendations
6
Will produce a
final report in
2020, with an
update to the
G20 in 2019.
Outlines framework
of design
considerations
regarding interim
measures
9. 9 | Taxation of the digitalized economy
Five categories of national action
What we are seeing around the world
Alternative PE thresholds
Argentina, India, Israel, Italy,
Saudi Arabia, Slovakia
!! Watch list !!
ASEAN Countries, EU countries, Saudi
Arabia (SDP), Taiwan, UK, US (South Dakota
vs. Wayfair)
Equalization levies/turnover
taxes
Austria, Greece, Hungary, India,
Italy
Application of VAT/GST
Argentina (intermediary to
collect), Australia, Belarus, Chile
(anticipated) New Zealand,
Singapore, Thailand, Turkey (!)
Withholding taxes (new or
increased)
China, Malaysia, Poland, South
Africa, Taiwan, Thailand, Ukraine
Specific anti-abuse regimes
Australia, New Zealand,
UK, US
10. 10 | Taxation of the digitalized economy
Digital Indirect Tax Trends
► Digital economy is raising complex issues for VAT systems
► OECD (November 2015): “International VAT/GST Guidelines” published with a heavy
focus on the place of supply of cross-border supplies of services and intangibles and the
application of the principles of destination and neutrality
► Trend toward digital supplies becoming taxable in the country of consumption
► Businesses increasingly needing to make VAT decisions in real time (at the point
of sale)
► Policymaking is developing – typical developments:
► Joint and several liability for online marketplaces
► Active searches for non-established ESS suppliers
► Removal of low value import thresholds
► Tax authorities are going digital
► Plus increasing inter-governmental cooperation
► Reputational risk rising
11. 11 | Taxation of the digitalized economy
Recent indirect tax developments
► B2B ESS
► Russia
► South Africa
► Switzerland
► Low value import
thresholds
► Australia
► EU
► Switzerland
► UK
► Online
marketplaces
► Australia
► Germany
► UK
► Digital
transaction tax
► Italy
► Real-time
reporting
► China
► LATAM
► Russia
► Spain
► B2C ESS
► Argentina
► Australia
► GCC
► Israel
► Turkey
12. 12 | Taxation of the digitalized economy
Sales tax considerations: The US expansions to
the definition of nexus to no longer require
physical presence
► Affiliate nexus: Remote seller of taxable tangible personal
property or services must register and collect tax based on
relationship with in-state retailer (e.g., sell under same or
similar trademarks)
► Click-through: Nexus with the state is created if an in-state
online business leads a customer via (click-through) links to an
out-of-state business
► Marketplace facilitator: Compels or coerces operators of an
internet marketplace (website where multiple sellers can list
and sell their products) to calculate, collect, and remit sales tax
for certain sales of tangible goods conducted on their platforms
► Consumer Noticing Requirements (Type 1): Retailers must
notify consumer that use tax is due on purchase despite the
fact that the retailer is not required to collect
► Consumer Noticing and State Reporting Requirements (Type
2): Remote retailers must provide information to the state
and/or customer, rather than requiring the remote retailer to
collect the use taxes themselves
► “Cookie nexus”: Interests in or use of in-state software (e.g.,
“apps”) and ancillary data (e.g., “cookies”) distributed to or
stored on computers or other physical communications devices
of vendor’s in-state customers constitutes a physical presence
► Economic presence: Retailer is deemed to have nexus with a
state, regardless of whether it has any physical presence in the
state, if it makes a certain number or dollar amount of sales
into the state
State jurisdiction to
tax
Physical
presence
standard
Attributional
nexus
Economic
nexus
Click-through
nexus
Notice and
reporting
Affiliate nexus
Market-place
provider/facilita
tor
Cookie nexus
In order to be taxed, the taxpayer needs to
have nexus with the state. Over time, what can
create nexus has expanded well beyond the
physical presence of Quill.
13. 13 | Taxation of the digitalized economy
European Commission’s “interim” solution
Digital Services Tax: 3% tax on gross revenues
In
scope
Less clear
Base and rate
► Levied on gross revenues
► Applied at a uniform rate of 3%
across the EU Member States
Thresholds
► The entity has total annual
worldwide revenues of €750m or
more; and
► The entity has annual EU taxable
revenues of €50m or more
Timing
► Member States adopt by
December 31, 2019
► Member States apply from
January 1, 2020
Out of
scope
► The placing on a digital interface of advertising targeted at
users of that interface; (channel owner not taxed on
revenue share from ads).
► Making available to users of a multi-sided digital interface that
allows users to find other users and to interact with them, and
which may also facilitate the provision of underlying supplies
of goods or services directly between users; (user revenues
not taxed)
► Transmission (for consideration) of data collected about
users and generated from users' activities on digital
interfaces.
► Online marketplaces without user-to-user selling
► Payment providers/processors
► Transactions between members of a consolidated group
► Financial Services regulated in Directive 2014/65/EU
► (Some but not all) crowdfunding
► Bundled or hybrid activities
► Social media forums with
user selling occurring but
no commission paid?
► Companies deriving
business intelligence value
from business users
► Companies deriving value
from non-internet sources
(e.g., connected cars)
► Unregulated financial
services
14. 14 | Taxation of the digitalized economy
Digital Services Tax
Challenges (a selection)
Different margins for
different business /
parts of the business
life cycle
Potential economic
incidence of taxation
on business – loss
making businesses?
Interim measure
may prove to not be
temporary
Double and over
taxation
May actually
encourage unilateral
moves
Unintended
consequences?
Deductibility
requires profitability
(or deferral)
Potentially
discriminatory
No reward to IP
developer/reward to
investor/value on non-
EU, user contributions
(etc)
Defining location of
users/possible to
comply with?
Unconsolidated joint
ventures?
No concept of
differing value-per-
user
15. 15 | Taxation of the digitalized economy
HM Treasury approach
Corporate tax and the digital economy – consultation and position paper
Users creating value:
► Generation of content by users that supports a business’ ability to attract
and retain users and generate revenue
► Deep engagement with the platform allowing tailoring of platform and
content and collection of valuable behavioral data
► Development of networks through engagement and actions that create
connections between users
► Contribution to a business’ brand through provision of content, goods or
services and through moderation and the rating of content
Potential approaches
► Define the characteristics through which users create value and then tax the businesses where
such characteristics are most relevant
► Define the categories of business which derive most value from user participation; this could
include social media platforms, search engines and online marketplaces;
► Define revenue streams commonly generated from user participation in such businesses, such as
online advertising revenues
16. 16 | Taxation of the digitalized economy
The US perspective
US
perspective
► Permanent establishment issues are no longer a
factor in the digital tax debate because the largest
MNEs have shifted or are in the process of shifting to
structures that use local low-risk distributors to report
income on locally filed tax returns, relying on transfer
pricing principles to determine how much profit to
report.
► The only remaining issues concern how much profit
should be allocated to the jurisdiction where
customers are located.
► There is no principled basis for arguing that a different
amount of profit should be allocated to a low-risk
distributor of digital services located in France as
compared to a luxury goods manufacturer’s low-risk
distributor located in the US.
► In the absence of a principled distinction between
those business models, the US does not believe it is
appropriate to have a separate tax regime limited to
digital business, and that “Special regimes aimed at
digital business models are not an appropriate way to
go.”
“I have stated my concerns
with Amazon long before the
election. Unlike others, they
pay little or no taxes to state a
local governments, use our
postal system as their
delivery boy (causing
tremendous loss to the US),
and are putting many
thousands of retailers out of
business! “
President Trump
“The US firmly opposes
proposals by any country to
single out digital companies”
US Treasury Secretary
Steven Mnuchin
17. 17 | Taxation of the digitalized economy
Significant Digital Presence (“Digital PE”)
European Commission’s proposed long term solution
Supplies
► Services delivered
over the internet or
an electronic
network
► Nature of which
renders their
supply essentially
automated and
involving minimal
human intervention
and impossible to
ensure in the
absence of IT
► Lists of services
specifically
included and
excluded
1 Through a
digital
interface
► Software,
including a
website and
applications,
including mobile
apps
2 Thresholds
exceeded
► One of:
► Annual revenues
of EUR 7m from
digital services,
► 100,000 users of
digital services,
or;
► Number of
business
contracts for
digital services
concluded in
period exceeds
3,000.
3 Profit split
applied
► Profit split method
will look to factors
such as R&D cost,
marketing cost,
number of users,
data collected, etc.
► Amend CCCTB for
these proposals
Rate
► CIT rate of Member
State applied
54
18. 18 | Taxation of the digitalized economy
Significant Digital Presence
Activities in scope: Annex II of the proposal
► Website hosting and webpage hosting
► Automated, online and distance maintenance of programs
► Remote systems administration
► Online data warehousing where specific data is stored and
retrieved electronically
► Online supply of on-demand disc space
► Accessing or downloading software (including
procurement/accountancy programs and anti-virus software)
plus updates
► Software to block banner adverts showing, otherwise known
as Bannerblockers
► Download drivers, such as software that interfaces
computers with peripheral equipment (such as printers)
► Online automated installation of filters on websites
► Online automated installation of firewalls
► Accessing or downloading desktop themes
► Accessing or downloading photographic or pictorial images
or screensavers
► The digitized content of books and other electronic
publications, subscription to online newspapers and journals
► Weblogs and website statistic
► Online news, traffic information and weather reports
► Online information generated automatically by software from
specific data input by the customer, such as legal and
financial data, (in particular such data as continually updated
stock market data, in real time)
► The provision of advertising space including banner ads on a
website/web page
► Use of search engines and Internet directories
► Accessing or downloading of music on to computers and
mobile phones
► Accessing or downloading of jingles, excerpts, ringtones,
or other sounds
► Accessing or downloading of films
► Downloading of games on to computers and mobile phones
► Accessing automated online games which are dependent on
the Internet, or other similar electronic networks, where
players are geographically remote from one another
► Automated distance teaching dependent on the Internet or
similar electronic network to function and the supply of which
requires limited or no human intervention, including virtual
classrooms, except where the internet or similar electronic
network is used as a tool simply for communication between
the teacher and student
► Workbooks completed by pupils online and marked
automatically, without human intervention.
i.e., everything …
19. 19 | Taxation of the digitalized economy
The Commission’s proposals
Deciphering the timing
2018 2019 2020 Beyond
Digital Services Tax (DST)
Significant Digital
Presence(SDP)
Common Consolidated
Corporate Tax Base
(CCCTB)
OECD Model Tax
Convention changes?
20. 20 | Taxation of the digitalized economy
What to expect next from the EU
► Delivered via a stand-alone Directive –
Article 113 of the TFEU (other forms of
indirect taxation).
► Uncertainty on dates : Member States shall
adopt and publish, by [31 December 2019.]
at the latest, the laws, regulations and
administrative provisions necessary to
comply with this Directive and that they shall
apply those provisions from [1 January
2020.]
► Requires adoption in the Council by
unanimity
► Enhanced cooperation not foreseen at
this stage
► Possibility for a group of like-minded
nations to group together independently
► Also delivered via a Directive, under Article
115 of the Treaty for the Functioning of the
European Union (direct tax on net profits).
► Member States to adopt and publish, by 31
December 2019 at the latest, the laws,
regulations and administrative provisions
necessary to comply with this Directive and
to apply those provisions from
1 January 2020 with respect to tax periods
beginning on or after that date.
► Also requires adoption in the Council by
unanimity.
► “Should be included in the Common
Consolidated Corporate Tax Base
(CCCTB) negotiations”.
Digital Services Tax Significant Digital Presence
21. 21 | Taxation of the digitalized economy
Recap
► This is not about abuse or avoidance; it is about taxing retained profits and
the division of taxing rights
► It is not about taxing the consumer
► Many (but not all) countries agree on broad areas of focus – Scale without
mass/intensive use of IP/user/data value
► This is a very political exercise (trade and tariffs, US tax reform, CCCTB,
European Parliament elections, etc.); many countries now realize that there
may be significant local implications of Commission proposals
► … But many Member States may not be willing to use their veto on this
issue, retaining it for more substantial future issues
► Comprehensive reform will take significant time and will require treaty change
– which is also driving a cooling of some countries
► But lack of unanimity on gross revenues tax may actually drive widespread
unilateral actions if Commission continues to push it
► Unilateral actions continue – in and outside of the EU