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

Abstract

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

Suggested Citation

Parrilli, Davide Maria, 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, Available at SSRN: https://ssrn.com/abstract=1246582

Davide Maria Parrilli (Contact Author)

time.lex ( email )

7 rue Joseph Stevens
Brussels, 1000
Belgium

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