Grid and Taxation: The Server as Permanent Establishment in International Grids
GECON 2008, LNCS 5206, J. Altmann, D. Neumann, T. Fahringer, eds., pp. 89-102, Springer-Verlag Berlin Heidelberg 2008
14 Pages Posted: 23 Aug 2008
Tax issues can be a great barrier to the development of international Grids and can be perceived as an obstacle for ICT companies. Provided this fact, the scope of this paper is to analyse the concept of server (to the ends of income taxation) in case of international Grid infrastructures, in the light of the findings of the Organisation for Economic Cooperation and Development (Model Tax Convention and Commentaries) and of the practices so far developed in some countries and, in particular, to assess whether any server can be considered to be a permanent establishment of the company acting as Grid provider, with all its consequences in terms of tax liability.
Keywords: taxation, server, permanent establishment
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