Corporate Income Tax Challenges Arising From Digitalised Business Models

In this study, we investigate how digitalised business models cause tax challenges due to a deviation between the place of value creation and the place of taxation. Using 90 cases identified in the literature, we show how digital technologies change business models. Based on the cases we conduct a normative analysis in that we determine in which cases a deviation be-tween the place of value creation and the place of taxation occurs. We further conduct a cross-case analysis to determine common conditions leading to tax challenges. Our study suggests that divergence between the location of value creation and nexus occurs if (1) data is collected, (2) at a place at which neither one of the participating parties creates a nexus and (3) a product or service is offered based on the data, leading to additional income for the company.

Keywords: digitalised economy, BEPS, value creation, digitalised business models, tax challenges

JEL Classification: H21, H25

Suggested Citation: Suggested Citation

Bauer, Georg and Fritz, Jil and Schanz, Deborah and Sixt, Michael, Corporate Income Tax Challenges Arising From Digitalised Business Models (March 7, 2019). Available at SSRN: https://ssrn.com/abstract=3348544 or http://dx.doi.org/10.2139/ssrn.3348544