EU corporate taxation in the digital era – the road to a new international order by Vieri Ceriani published by CEPS-ECMI (2023)
International coordination of corporate income tax has traditionally been based on the individuation of separate entities that perform economic activities within a multinational group: taxation is linked to the place where all or part of a company’s business activities are physically carried out, either through a legal entity or through a permanent establishment. Over recent years, however, growing internationalisation – partly due to digitalisation – and the arrival of big-tech companies, have resulted in changes in companies’ business models. This includes their ability to provide digital services and create value without being physically based in a certain tax jurisdiction, and to recoup it through intellectual property rights for digital users. This has raised concerns about tax avoidance, brought challenges to the rules for taxing international business income, and sparked the debate on whether such rules are still fit for purpose.
