scholarly journals On development of the concept of permanent establishment in the age of digitalization within the context of taxation of cross-border activity

2020 ◽  
pp. 6-8
Author(s):  
Svitlana KOVALSKA
Keyword(s):  
International Business ◽  
International Taxation ◽  
Final Report ◽  
Fair Allocation ◽  
International Level ◽  
Economic Activities ◽  
Corporate Tax ◽  
Research Papers ◽  
Cross Border ◽  
Permanent Establishment

Introduction. The article considers modern developments of the concept of permanent establishment in the context of taxation of cross-border activities. The concept which was developed in 1920s has remained virtually unchanged since the early 1960s, despite the huge changes in the way that international business is conducted since then. However, as nowadays acknowledged, digitalization of business creates tax challenges, in particular, in a way taxing rights are distributed between the states. These challenges also raise questions regarding the ability of the existing international tax framework to determine where economic activities are carried out and value is created for corporate tax purposes. The purpose of the paper is to consider the developments around the concept of permanent establishment to address tax challenges of the digital economy, in particular, a new nexus for permanent establishment related to digital activities. Results. The purpose of the international taxation system’s design is to ensure fair allocation of taxing rights between different jurisdictions. While the general consensus is that taxation should take place where the value is created the current tax framework lack mechanisms which would ensure such taxation. This issue has been raised in research papers and addressed by the Organization for Economic Cooperation and Development. Although the BEPS Final Report identified tax challenges created, inter alia, by outdated concept of permanent establishment no common consensus was reached regarding measures to be taken to address those challenges. However, as a result of further work the concept of a new nexus was proposed and is being currently discussed. Conclusion. Introduction of the new nexus on an international level will provide the basis for fair allocation of taxing rights between states and will help to prevent unilateral measures taken by different countries to ensure taxation of digital activities within their jurisdictions that may create further distortions.

Cross-Border Intra-Group Hybrid Finance and International Taxation

2010 ◽  
Author(s):  
Eva Eberhartinger ◽  
Erich Pummerer ◽  
Andreas Göritzer
Keyword(s):  
International Taxation ◽  
Cross Border

Reclaiming their socio-economic space in African culture : Shona Women Cross-Border Traders of Zimbabwe

2021 ◽  
Vol 2 (1) ◽  
pp. 65-82
Author(s):  
Enna Sukutai Gudhlanga
Keyword(s):  
Well Being ◽  
Global South ◽  
Customary Law ◽  
African Woman ◽  
African Culture ◽  
Economic Activities ◽  
Cross Border ◽  
Success Stories ◽  
The Family ◽  
The Cross

The advent of colonialism relegated the traditional African woman to the fringes of the family and society through codified customary law. The Shona women of Zimbabwe were some of the worst affected as they were re-defined as housewives who had to rely on their husbands for the up-keep of the family. However, in as much as globalisation has been accused of having brought some crisis on the African continent and side-lined a significant number of indigenous players, for the African woman in the global south it has brought some form of re-awakening. Globalisation seems to have re-opened the avenues for Shona women and enabled them to re-negotiate their entry back into the economic activities of the family and the public sphere. Despite the general lack of interest in the activities of women and in the strategies used by the poor for survival, it is a known fact that Shona women have become a force to reckon with in terms of cross-border trading in Zimbabwe. This research was prompted by the general hub of activity at the country's borders before the onslaught of the COVID-19 pandemic and the predominance of women traders who traverse the borders but whose activities have either not attracted enough attention to get their work recognised, or simply because they are taken for granted. Despite such strides, women in the cross-border trading business have instead garnered a certain stigma around them to the extent that the magnitude of their work is largely unrecognised. Yet elsewhere, the significance of women in informal trade is well documented. This study argues that women have not been left out in the global arena of trade. Desai (2009) acknowledges that the global economic openings in the informal sector have afforded women the opportunity to become active players in the markets of the global South. It is the aim of this research to investigate how globalisation has influenced the nature of the activities of Shona women in the cross-border trading business in Zimbabwe and their impact on the social well-being of the family and the nation’s economy at large. The research is largely qualitative in nature. Purposively selected Shona female cross-border traders at the Gulf Complex and Copacabana Market in Harare were interviewed before the COVID pandemic. The study revealed that the transnational activities of these Zimbabwean women are more wide-spread than has been anticipated. The study also revealed that women are unrecognised pillars in the economy of Zimbabwe as reflected in their success stories that have benefited Zimbabwe as a country. The study was informed by Africana Womanist theory which is embedded in African culture with special leaning on Ubuntu/ Unhu philosophy which recognises the complementary roles and partnerships of both men and women in resolving society's challenges.

scholarly journals TAXING DIGITAL ADVERTISING: A PROPOSAL TO INDONESIA

Scientax ◽  
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.

International business and cross-border education: a case of the Janus face of globalisation?

2011 ◽  
Vol 13 (2) ◽  
pp. 105
Author(s):  
Gaby Ramia ◽  
Simon Marginson ◽  
Erlenawati Sawir ◽  
Chris Nyland
Keyword(s):  
International Business ◽  
Cross Border

Cross-Border E-Commerce Security Issues and Protections

2021 ◽  
pp. 98-119
Author(s):  
Sumaiya Thaseen ◽  
Aswani Kumar Cherukuri ◽  
Aarshitha Kopparapu ◽  
Gopika Velu
Keyword(s):  
Resource Allocation ◽  
Market Share ◽  
International Business ◽  
Optimal Solutions ◽  
Security Issues ◽  
Cross Border ◽  
Target Segment ◽  
Marketing Costs ◽  
The Impact

E-commerce enables brands to reach their customers globally anytime they want to shop and provide convenience to the busy and demanding customer. These days, cross-border e-commerce is accelerating faster compared to domestic e-commerce. Cross-border e-commerce is considered to be a separate body which has its own budget and resource allocation. It focuses on new opportunities that help in gaining market share and sales. This can result in lower marketing costs in the long-term. India contributes 0.8% of a $600 billion global cross-border e-commerce market. Thus, this is an enormous target segment that exporters can focus to expand their international business. There are numerous advantages of cross-border e-commerce, which will be discussed in detail in this chapter. This chapter discusses the meaning of GDPR, the subjects of GDPR, and the effects of GDPR on individuals and organizations. This chapter also states the impact of GDPR on different fields and technologies. In addition, the major cross-border e-commerce security issues are analyzed, and optimal solutions are discussed.

scholarly journals Abuses and Penalties of a Corporate Tax Inversion

2019 ◽  
Vol 7 (1) ◽  
pp. 5
Author(s):  
James Yang ◽  
Leonard Lauricella ◽  
Frank Aquilino
Keyword(s):  
Multinational Corporations ◽  
International Taxation ◽  
Internal Revenue Service ◽  
Tax Law ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Tax Savings ◽  
Treasury Department ◽  
The U.S

There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as “corporate tax inversion”. This paper discusses the abuses and penalties of this phenomenon. It is rooted in some deficiencies in the U.S. tax law. This paper points out that the U.S. has the highest corporate tax rate in the world. It imposes tax on worldwide income. It permits deferral of tax on foreign-sourced income until dividends are repatriated back to the U.S. As a result, it creates tax loopholes. This paper reveals six actual cases of corporate tax inversion. This practice has triggered the Congress to enact §7874, the Internal Revenue Service (IRS) to issue Notices IR 2014-52 and IR 2015-79, and the U.S. Treasury Department to promulgate TD 9761. This paper investigates some details of these penalties. This paper further demonstrates an example in determining the amount of tax savings by engaging in a corporate tax inversion. It also offers many strategies.

scholarly journals What is Unilateralism in International Taxation?

AJIL Unbound ◽  
2020 ◽  
Vol 114 ◽  
pp. 260-264
Author(s):  
Wei Cui
Keyword(s):  
International Business ◽  
International Taxation ◽  
The Other ◽  
Profit Shifting ◽  
High Stakes ◽  
Political Resources ◽  
International Coordination ◽  
International Tax ◽  
The One

The Organisation for Economic Co-Operation and Development (OECD) recently emerged as the site of unprecedented, multilateral, and seemingly high-stakes negotiations about the future of international business income taxation. Judging by the political resources deployed in these negotiations, international tax has entered unchartered territory. Ruth Mason offers a timely and balanced portrayal of the OECD process so far. But explanations of this process remain eminently contestable. On the one hand, international institutions that address externalities from uncoordinated actions and produce mutual benefits for participating nations can be highly stable. On the other hand, the OECD has struggled, whether in its Base Erosion and Profit Shifting (BEPS) and post-BEPS initiatives or during the pre-BEPS era, to articulate the goals for which international coordination in taxation is needed. By many accounts, recent discussions at the OECD are motivated mainly by the desire to stop foreign imposition of taxes on U.S. companies, or, as the other side of the same coin, to avert the wrath of the single hegemonic power in international tax. What is the best characterization of this conflict? I believe that understanding the underlying subject matter for international coordination, as opposed to merely the institutions that might facilitate such coordination, is required for identifying the coming transformation of international tax.

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