Does draft HMRC guidance trap non-residents with a 'permanent establishment'?

AbstractOne flowering specimen of Ophrys bertolonii (s. str.) — a plant with a Circum-Adriatic distribution and hitherto unknown in other regions — was found on 7th May 2010 in the vicinity of Kunadacs (Central Hungary; N 47°00′ E 19°17′). The nearest known populations of this Mediterranean plant inhabit the Adriatic coast (ca. 450 km away) in Croatia, therefore this new occurrence represents a significant long distance dispersal event. The circumstances of the occurrence argue against introduction, but we can not decide now whether this new appearance is temporary or permanent. The permanent establishment of this strictly entomophilous plant requires the presence of its specific pollinator in the close neighbourhood of the habitat. However, no pollination was observed on the three flowers of the plant until 9th May, and one day later the stem had disappeared most likely due to grazing. Whatever the long-term fate of the plant is, this discovery represents a significant long distance (jump) dispersal event, and testifies to the dispersal ability of Ophrys species. Additionally, the appearance of a mature Adriatic plant in Central Europe fits well into the currently observed, climate change driven northward expansion of European orchids, therefore this finding most likely reflects a growing Mediterranean-like climatic influence in the region.

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TAXING DIGITAL ADVERTISING: A PROPOSAL TO INDONESIA

Scientax ◽

10.52869/st.v3i1.103 ◽

2021 ◽

Vol 3 (1) ◽

pp. 1-28

Author(s):

Galih Ardin

Keyword(s):

Southeast Asia ◽

Oecd Countries ◽

Digital Economy ◽

Tax Revenue ◽

Indonesian Government ◽

Cross Border ◽

Permanent Establishment ◽

The World ◽

New Challenges ◽

Taxation System

Tax on digital economy activities has become a widely discussed issue in the world because of the limitation on the permanent establishment concept in anticipating the digital economy's externalities. The failure of OECD countries to reach digital economic taxation agreements also caused these countries to take unilateral measures in securing their respective interests. Indonesia, as a country with considerable digital economy value in the Southeast Asia region, plans to implement the significant economic presence concept to secure its tax revenue that cannot be captured by PE concept in the digital cross-border transaction. However, the implementation of this new nexus could generate new challenges in the Indonesia taxation system. This study seeks to provide alternatives to the Indonesian government regarding the taxable presence and taxation methods on the digital economy, especially digital advertising, by conducting examination and evaluation through current nexuses, the international proposals, and other countries' experience in addressing tax challenges in the digital advertising.

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