Double taxation of corporate profits distorts the choice of business form, the debt and equity capitalization of companies, and the character and timing of profits distributions. To avoid these distortions, countries adopt so-called integrated corporate tax regimes. But countries almost always...

Tax and the Digital Economy' provides a detailed analysis of the impact of the digitalization process on tax policy, tax administration and taxpayers. The increasingly digitalized global economy is undermining the usefulness of many traditional tax concepts. In addition to the issues of double...

"Should I stay or should I go… "? The implementation of the EU's internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as "an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured", together with...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...