The 2019 OECD Proposals for Addressing the Tax Challenges of the Digitalization of the Economy: An Assessment

Abstract

The IBFD Task Force on the Digital Economy prepared an earlier version of this document for the purpose of commenting on the policy, technical and administration issues raised by each of the Three Proposals [hereinafter: the Proposals] contained in Section 2 of the Public Consultation Document "Addressing the Tax Challenges of the Digitalization of the Economy", released by the OECD on 13 February 2019 [hereinafter: the 2019 OECD Public Consultation Document].

This study contains the final version of the document elaborated by the IBFD Task Force on the Digital Economy, which revises the content of the original document and enriches it with consideration of select issues drawn from the documents submitted by other international tax experts to the OECD, as well as with the content of the debate held on 13 and 14 March 2019 at the OECD headquarters in Paris on the 2019 Public Consultation Document.

In principle, the authors have formulated their comments by following the order of the questions included in the OECD Public Consultation Document. Nevertheless, these questions raise general and specific issues, some of which are common to two or more of the Proposals. For this reason, the authors have drafted a general overview in section 1, before analysing the questions raised by each Proposal. Since the core analysis of the questions is spread throughout sections 2, 3 and 4, these questions have essentially a parallel structure. In addition, before addressing each question of the 2019 OECD Public Consultation Document, each section of this document includes a grey box referring to the specific question being addressed.

Keywords: Taxation, Tax law, European taxation

JEL Classification: K33, K34, F13, E62, D78, E62, F02, F23, F42, H20, H22, H23, H25, H26, H87, O19, O23, O24