Taxation of Information and the Data Revolution
109 Iowa L. Rev. 1959 (2024)
University of Florida Levin College of Law Research Paper No. 25-24
59 Pages Posted: 11 Apr 2023 Last revised: 17 Sep 2025
Date Written: March 1, 2023
Abstract
Existing and universal income tax rules are inherently incompatible with an economy in which information-based transactions play a significant role. This Article contends that income taxation is incapable of taxing information effectively. It goes on to argue that this incapability currently necessitates reform, and it offers three viable paths to such reform: consumption taxation, data taxes, and formulary taxation. The Article concludes that formulary taxation is currently the most desirable and plausible path to effective reform, owing to its promise to best stabilize and maintain the legitimacy of the international tax regime.
Keywords: Information , Data , privacy, tax, international taxation , international tax regime , taxation of intangibles
JEL Classification: K34 , K33 , K20
Suggested Citation: Suggested Citation