E-commerce and Source-based Income Taxation

E-commerce and Source-based Income Taxation

Author: Dale Pinto

Publisher:

Published: 2003

Total Pages: 244

ISBN-13:

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The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. Characteristics of electronic commerce include the expected reduction in the need for certain intermediaries in the business process, as well as the borderless and intangible nature of the Internet, which allows a business to earn income without it having to maintain a physical presence in the market territory. In light of these characteristics it is not difficult to see how arguments calling for the abandonment of source-based taxation continue to be raised. While this book accepts these observations as being valid, nevertheless it will be argued by its author that source-based taxation is theoretically justifiable for income that arises from international transactions that are conducted in an electronic commerce environment. However, it will also be argued that the way in which the source of income is defined needs to be reconceptualized because the application of source-based taxation under traditional principles may be rendered problematic in light of certain characteristics of electronic commerce that are significant from a tax perspective.


Book Synopsis E-commerce and Source-based Income Taxation by : Dale Pinto

Download or read book E-commerce and Source-based Income Taxation written by Dale Pinto and published by . This book was released on 2003 with total page 244 pages. Available in PDF, EPUB and Kindle. Book excerpt: The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. Characteristics of electronic commerce include the expected reduction in the need for certain intermediaries in the business process, as well as the borderless and intangible nature of the Internet, which allows a business to earn income without it having to maintain a physical presence in the market territory. In light of these characteristics it is not difficult to see how arguments calling for the abandonment of source-based taxation continue to be raised. While this book accepts these observations as being valid, nevertheless it will be argued by its author that source-based taxation is theoretically justifiable for income that arises from international transactions that are conducted in an electronic commerce environment. However, it will also be argued that the way in which the source of income is defined needs to be reconceptualized because the application of source-based taxation under traditional principles may be rendered problematic in light of certain characteristics of electronic commerce that are significant from a tax perspective.

Global Perspectives on E-Commerce Taxation Law

Global Perspectives on E-Commerce Taxation Law

Author: Subhajit Basu

Publisher: Routledge

Published: 2016-04-22

Total Pages: 344

ISBN-13: 1317127420

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In its most advanced form, e-commerce allows unidentified purchasers to pay obscure vendors in 'electronic cash' for products that are often goods, services and licenses all rolled into one. This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field. With its focus on the broader issues surrounding the expansion of e-commerce and its attention to the problems arising internationally in this field, Global Perspectives in E-Commerce Taxation Law will appeal to scholars worldwide.


Book Synopsis Global Perspectives on E-Commerce Taxation Law by : Subhajit Basu

Download or read book Global Perspectives on E-Commerce Taxation Law written by Subhajit Basu and published by Routledge. This book was released on 2016-04-22 with total page 344 pages. Available in PDF, EPUB and Kindle. Book excerpt: In its most advanced form, e-commerce allows unidentified purchasers to pay obscure vendors in 'electronic cash' for products that are often goods, services and licenses all rolled into one. This book considers the implications for the domestic and international tax systems of the growth of e-commerce. It covers a wide variety of activities, from discussion of the principles governing direct and indirect taxation, to explanation of the implementation and use of e-commerce on the part of businesses as well as the application of existing tax principles in this field. With its focus on the broader issues surrounding the expansion of e-commerce and its attention to the problems arising internationally in this field, Global Perspectives in E-Commerce Taxation Law will appeal to scholars worldwide.

Taxing Global Digital Commerce

Taxing Global Digital Commerce

Author: Arthur Cockfield

Publisher: Kluwer Law International B.V.

Published: 2019-11-07

Total Pages: 506

ISBN-13: 9041167110

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Digital commerce – the use of computer networks to facilitate transactions involving the production, distribution, sale, and delivery of goods and services – has grown from merely streamlining relations between consumer and business to a much more robust phenomenon embracing efficient business processes within a firm and between firms. Inevitably, the related taxation issues have grown as well. This latest edition of the preeminent text on the taxation of digital transactions revises, updates and expands the book’s coverage. It includes a detailed and up-to-date analysis of income tax and VAT developments regarding digital commerce under the OECD and G20 Base Erosion and Profit Shifting (BEPS) reforms. It explores the implications of digital commerce for US state sales and use tax regimes resulting from the 2018 US Supreme Court decision in Wayfair. It discusses cross-border tax in the United States while continuing to focus on tax developments throughout the world. Analysing the practical tax consequences of digital commerce from a multijurisdictional perspective, and using examples to illustrate the application of different taxes to digital commerce transactions, the book offers in-depth treatment of such topics as the following: how tax rules governing cross-border digital commerce are increasingly applied to all cross-border activities; how tax rules and institutional processes have evolved to confront challenges posed by digital commerce; how an emerging ‘tax war’ is developing whereby different countries are unilaterally imposing new tax rules on cross-border digital commerce; how technology enhances tax and cross-border tax information exchanges; how technology reduces both compliance and enforcement costs; cross-border consumption tax issues raised by cloud computing; and different approaches to the legal design of VAT place of taxation rules. The authors offer insightful views on the likely development of new approaches to taxing cross-border digital commerce. This edition, while building on the analysis of the relationship between traditional tax laws and the Internet in the first edition and its predecessors, contains a more explicit and systematic consideration of digital commerce issues and the ongoing policy responses to them. Tax professionals and academics everywhere will welcome the important contribution it makes towards the design of cross-border tax rules that are both conceptually sound and practical in application. ‘A tour de force … much larger and richer than its predecessors … a massive contribution to the growing literature on the taxation of e-commerce.’ – Rita de la Feria, British Tax Review ‘Provides important understandings for ongoing policy discussions … I would warmly recommend.’ – P. Rendahl, World Journal of VAT/GST Law


Book Synopsis Taxing Global Digital Commerce by : Arthur Cockfield

Download or read book Taxing Global Digital Commerce written by Arthur Cockfield and published by Kluwer Law International B.V.. This book was released on 2019-11-07 with total page 506 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digital commerce – the use of computer networks to facilitate transactions involving the production, distribution, sale, and delivery of goods and services – has grown from merely streamlining relations between consumer and business to a much more robust phenomenon embracing efficient business processes within a firm and between firms. Inevitably, the related taxation issues have grown as well. This latest edition of the preeminent text on the taxation of digital transactions revises, updates and expands the book’s coverage. It includes a detailed and up-to-date analysis of income tax and VAT developments regarding digital commerce under the OECD and G20 Base Erosion and Profit Shifting (BEPS) reforms. It explores the implications of digital commerce for US state sales and use tax regimes resulting from the 2018 US Supreme Court decision in Wayfair. It discusses cross-border tax in the United States while continuing to focus on tax developments throughout the world. Analysing the practical tax consequences of digital commerce from a multijurisdictional perspective, and using examples to illustrate the application of different taxes to digital commerce transactions, the book offers in-depth treatment of such topics as the following: how tax rules governing cross-border digital commerce are increasingly applied to all cross-border activities; how tax rules and institutional processes have evolved to confront challenges posed by digital commerce; how an emerging ‘tax war’ is developing whereby different countries are unilaterally imposing new tax rules on cross-border digital commerce; how technology enhances tax and cross-border tax information exchanges; how technology reduces both compliance and enforcement costs; cross-border consumption tax issues raised by cloud computing; and different approaches to the legal design of VAT place of taxation rules. The authors offer insightful views on the likely development of new approaches to taxing cross-border digital commerce. This edition, while building on the analysis of the relationship between traditional tax laws and the Internet in the first edition and its predecessors, contains a more explicit and systematic consideration of digital commerce issues and the ongoing policy responses to them. Tax professionals and academics everywhere will welcome the important contribution it makes towards the design of cross-border tax rules that are both conceptually sound and practical in application. ‘A tour de force … much larger and richer than its predecessors … a massive contribution to the growing literature on the taxation of e-commerce.’ – Rita de la Feria, British Tax Review ‘Provides important understandings for ongoing policy discussions … I would warmly recommend.’ – P. Rendahl, World Journal of VAT/GST Law

Ecommerce and Cross Border Taxation

Ecommerce and Cross Border Taxation

Author: William L Richards Jr. S.J.D.

Publisher: First Edition Design Pub.

Published: 2015-01-21

Total Pages: 34

ISBN-13: 1622878221

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Electronic commerce by its very innovative nature has engendered a novel application of past precedents. In the application of concepts of cross border taxation, it embraces traditional questions of source and resident taxation. Initially these principles were developed domestically. What has transpired in the development has been an evolution of the Due Process and commerce clauses of the United States. This evolution of constitutional considerations resulted because electronic commerce made for a complex determination of which domestic state had jurisdiction to tax electronic commerce. It brushed up against precedent notions of how the Due Process and Commerce Clause had been analyzed in terms of activities sourced and effects upon those whose borders are crossed. Keywords: ECommerce, Taxation, Commerce Clause, Due Process, Trade or Business, Permanent Establishment, Treaty.


Book Synopsis Ecommerce and Cross Border Taxation by : William L Richards Jr. S.J.D.

Download or read book Ecommerce and Cross Border Taxation written by William L Richards Jr. S.J.D. and published by First Edition Design Pub.. This book was released on 2015-01-21 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: Electronic commerce by its very innovative nature has engendered a novel application of past precedents. In the application of concepts of cross border taxation, it embraces traditional questions of source and resident taxation. Initially these principles were developed domestically. What has transpired in the development has been an evolution of the Due Process and commerce clauses of the United States. This evolution of constitutional considerations resulted because electronic commerce made for a complex determination of which domestic state had jurisdiction to tax electronic commerce. It brushed up against precedent notions of how the Due Process and Commerce Clause had been analyzed in terms of activities sourced and effects upon those whose borders are crossed. Keywords: ECommerce, Taxation, Commerce Clause, Due Process, Trade or Business, Permanent Establishment, Treaty.

E-commerce and Source-based Income Taxation

E-commerce and Source-based Income Taxation

Author: Dale Pinto

Publisher: IBFD

Published: 2003

Total Pages: 260

ISBN-13: 9076078564

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The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment.


Book Synopsis E-commerce and Source-based Income Taxation by : Dale Pinto

Download or read book E-commerce and Source-based Income Taxation written by Dale Pinto and published by IBFD. This book was released on 2003 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt: The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment.

Source-Based Taxation of E-Commerce Income

Source-Based Taxation of E-Commerce Income

Author: Dennis Ndonga

Publisher:

Published: 2019

Total Pages:

ISBN-13:

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Rapid progressions in cross-border e-commerce has revolutionized international trade and made it possible for businesses to transact in a borderless Internet environment. However, most international tax treaties still apply source-based taxation principles, including the permanent establishment concept, in taxing income derived from international commerce. This article examines whether source-based taxation remains theoretically valid in the territorial taxation of cross-border e-commerce income. It analyses the application of the permanent establishment concept to e-commerce corporate income and reviews some of the existing challenges and the current responses to these challenges at the academic and international level.


Book Synopsis Source-Based Taxation of E-Commerce Income by : Dennis Ndonga

Download or read book Source-Based Taxation of E-Commerce Income written by Dennis Ndonga and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Rapid progressions in cross-border e-commerce has revolutionized international trade and made it possible for businesses to transact in a borderless Internet environment. However, most international tax treaties still apply source-based taxation principles, including the permanent establishment concept, in taxing income derived from international commerce. This article examines whether source-based taxation remains theoretically valid in the territorial taxation of cross-border e-commerce income. It analyses the application of the permanent establishment concept to e-commerce corporate income and reviews some of the existing challenges and the current responses to these challenges at the academic and international level.

eCommerce and the Effects of Technology on Taxation

eCommerce and the Effects of Technology on Taxation

Author: Anne Michèle Bardopoulos

Publisher: Springer

Published: 2015-03-31

Total Pages: 367

ISBN-13: 3319154494

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This book focuses on the impact of technology on taxation and deals with the broad effect of technology on diverse taxation systems. It addresses the highly relevant eTax issue and argues that while VAT may not be the ultimate solution with regard to taxing electronic commerce, it can be demonstrated to be the most effective solution to date. The book analyzes the application and the effectiveness of traditional income tax principles in contradistinction to VAT principles. Taking into account rapidly ameliorating technology, the book next assesses the compatibility between electronic commerce and diverse systems of taxation. Using case studies of Amazon.com and Second Life as well as additional practical examples, the book demonstrates the effectiveness of VAT in respect of electronic commerce and ameliorating technology in the incalculable and borderless realm of cyberspace.


Book Synopsis eCommerce and the Effects of Technology on Taxation by : Anne Michèle Bardopoulos

Download or read book eCommerce and the Effects of Technology on Taxation written by Anne Michèle Bardopoulos and published by Springer. This book was released on 2015-03-31 with total page 367 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book focuses on the impact of technology on taxation and deals with the broad effect of technology on diverse taxation systems. It addresses the highly relevant eTax issue and argues that while VAT may not be the ultimate solution with regard to taxing electronic commerce, it can be demonstrated to be the most effective solution to date. The book analyzes the application and the effectiveness of traditional income tax principles in contradistinction to VAT principles. Taking into account rapidly ameliorating technology, the book next assesses the compatibility between electronic commerce and diverse systems of taxation. Using case studies of Amazon.com and Second Life as well as additional practical examples, the book demonstrates the effectiveness of VAT in respect of electronic commerce and ameliorating technology in the incalculable and borderless realm of cyberspace.

Electronic Commerce and Multi-Jurisdictional Taxation

Electronic Commerce and Multi-Jurisdictional Taxation

Author: Richard Doernberg

Publisher: Springer

Published: 2001-09-19

Total Pages: 0

ISBN-13: 9789041116833

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Electronic Commerce and Multi-Jurisdictional Taxation (2001) is the successor to the widely-acclaimed Electronic Commerce and International Taxation (1999). The new edition contains expanded and enhanced consideration of the tax treatment of electronic commerce from both an income tax and a consumption tax perspective. Not only does the new edition provide a detailed and up-to-date analysis of VAT developments regarding e-commerce, but it also explores the implications of e-commerce for the US state and local sales and use tax regime. It discusses developments in Europe and the United States while enlarging its focus to include the tax treatment of e-commerce in China, India, Canada, Australia, and throughout the world. At the same time, the authors have deftly woven the latest OECD and European Community developments into the fabric of the book. There is no other book on the market today that analyzes the practical tax consequences of e-commerce with the multi-jurisdictional and multi-tax perspective of this insightful work by distinguished academics and practitioners Richard Doernberg, Luc Hinnekens, Walter Hellerstein, and Jinyan Li.


Book Synopsis Electronic Commerce and Multi-Jurisdictional Taxation by : Richard Doernberg

Download or read book Electronic Commerce and Multi-Jurisdictional Taxation written by Richard Doernberg and published by Springer. This book was released on 2001-09-19 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Electronic Commerce and Multi-Jurisdictional Taxation (2001) is the successor to the widely-acclaimed Electronic Commerce and International Taxation (1999). The new edition contains expanded and enhanced consideration of the tax treatment of electronic commerce from both an income tax and a consumption tax perspective. Not only does the new edition provide a detailed and up-to-date analysis of VAT developments regarding e-commerce, but it also explores the implications of e-commerce for the US state and local sales and use tax regime. It discusses developments in Europe and the United States while enlarging its focus to include the tax treatment of e-commerce in China, India, Canada, Australia, and throughout the world. At the same time, the authors have deftly woven the latest OECD and European Community developments into the fabric of the book. There is no other book on the market today that analyzes the practical tax consequences of e-commerce with the multi-jurisdictional and multi-tax perspective of this insightful work by distinguished academics and practitioners Richard Doernberg, Luc Hinnekens, Walter Hellerstein, and Jinyan Li.

International Taxation of Electronic Commerce

International Taxation of Electronic Commerce

Author: Richard A. Westin

Publisher:

Published: 2007

Total Pages: 0

ISBN-13: 9789041125101

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The bricks and mortar of commercial law as we know it are crumbling into dust. Electronic commerce sweeps away the very foundations of what was not so long ago our most solid, comfortable, and secure legal system. In its most advanced form e-commerce allows unidentified purchasers to pay obscure vendors, in `electronic cash,' for products that are often goods, services, and licenses all rolled into one. A payee may be no more than a computer that can take up `residence' anywhere at the drop of a hat; national boundaries are of no consequence whatsoever. Taxation authorities are understandably dismayed. This book, now in its second edition, is a minutely detailed overview of current reality in the worldwide huddle of revenue regimes as they try to cope with the most daunting challenge they have ever had to face. It analyzes a number of fast-moving trends in the behaviors of national taxation authorities, web-based companies, VoiP, certain low-tax (or no-tax) jurisdictions, and international organizations that have significant bearing on the future development of the taxation of e-commerce. These trends include the following: how United States domestic and international tax rules are being interpreted in the effort to accommodate e-commerce; the powerful retailers' lobby against the moratorium on U.S. state and local sales tax on Internet transactions; how VAT rules in EU countries and other jurisdictions are being restructured to accommodate international e-commerce; new theories of income and payment characterization, and in particular the influential OECD ongoing study; and the crucial discussion over what constitutes a `permanent establishment for tax purposes.


Book Synopsis International Taxation of Electronic Commerce by : Richard A. Westin

Download or read book International Taxation of Electronic Commerce written by Richard A. Westin and published by . This book was released on 2007 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The bricks and mortar of commercial law as we know it are crumbling into dust. Electronic commerce sweeps away the very foundations of what was not so long ago our most solid, comfortable, and secure legal system. In its most advanced form e-commerce allows unidentified purchasers to pay obscure vendors, in `electronic cash,' for products that are often goods, services, and licenses all rolled into one. A payee may be no more than a computer that can take up `residence' anywhere at the drop of a hat; national boundaries are of no consequence whatsoever. Taxation authorities are understandably dismayed. This book, now in its second edition, is a minutely detailed overview of current reality in the worldwide huddle of revenue regimes as they try to cope with the most daunting challenge they have ever had to face. It analyzes a number of fast-moving trends in the behaviors of national taxation authorities, web-based companies, VoiP, certain low-tax (or no-tax) jurisdictions, and international organizations that have significant bearing on the future development of the taxation of e-commerce. These trends include the following: how United States domestic and international tax rules are being interpreted in the effort to accommodate e-commerce; the powerful retailers' lobby against the moratorium on U.S. state and local sales tax on Internet transactions; how VAT rules in EU countries and other jurisdictions are being restructured to accommodate international e-commerce; new theories of income and payment characterization, and in particular the influential OECD ongoing study; and the crucial discussion over what constitutes a `permanent establishment for tax purposes.

OECD Tax Policy Studies E-commerce: Transfer Pricing and Business Profits Taxation

OECD Tax Policy Studies E-commerce: Transfer Pricing and Business Profits Taxation

Author: OECD

Publisher: OECD Publishing

Published: 2005-05-12

Total Pages: 157

ISBN-13: 9264007229

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The increased speed and mobility of business activities and cross-border transactions resulting from internet usage has particular implications for applying transfer pricing methods and for taxing business profits. This book presents a two-part look at existing OECD positions on these issues.


Book Synopsis OECD Tax Policy Studies E-commerce: Transfer Pricing and Business Profits Taxation by : OECD

Download or read book OECD Tax Policy Studies E-commerce: Transfer Pricing and Business Profits Taxation written by OECD and published by OECD Publishing. This book was released on 2005-05-12 with total page 157 pages. Available in PDF, EPUB and Kindle. Book excerpt: The increased speed and mobility of business activities and cross-border transactions resulting from internet usage has particular implications for applying transfer pricing methods and for taxing business profits. This book presents a two-part look at existing OECD positions on these issues.