Comment on Selected Aspects of Proposals in Public Consultation Document on Addressing the Challenges of the Digitalization of the Economy

10 Pages Posted: 12 Mar 2019

Date Written: March 6, 2019

Abstract

This comment was filed in response to the G20/OECD Inclusive Forum’s Public Consultation Document on Addressing the Challenges of the Digitalization of the Economy. The comment supports a re-alignment of the division of corporate income between source and residence countries that is not restricted to digitalized businesses. The comment seeks to contribute to the discussion by outlining a framework for taxing a nonresident taxpayer that is “heavily involved in the economic life of a jurisdiction without a significant physical presence” and includes description of a methodology for attributing income to a non-physical permanent establishment using existing income tax principles.

Suggested Citation

Shay, Stephen E., Comment on Selected Aspects of Proposals in Public Consultation Document on Addressing the Challenges of the Digitalization of the Economy (March 6, 2019). Available at SSRN: https://ssrn.com/abstract=3349186 or http://dx.doi.org/10.2139/ssrn.3349186

Stephen E. Shay (Contact Author)

Harvard Law School ( email )

1563 Manssachusetts Avenue
Cambridge, MA 02138
United States

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