Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Law
Value Creation: A Constant Principle In A Changing World Of International Taxation, Jinyan Li, Nathan Jin Bao, Huaning Li
Value Creation: A Constant Principle In A Changing World Of International Taxation, Jinyan Li, Nathan Jin Bao, Huaning Li
Articles & Book Chapters
The authors consider the new nomenclature of value creation in terms of its meaning, theoretical basis, and importance in the context of the international taxation of business profits. The authors’ central claim is that the principle of value creation is a profound elaboration of the doctrine of economic allegiance, which is the theoretical basis for the current international tax system; and that international tax norms, such as the arm’s-length principle, are meant to give effect to the doctrine of economic allegiance (and now to the principle of value creation). As demonstrated by the Organisation for Economic Co-operation and Development/Group of …
Taxing The Digital Economy Post-Beps…Seriously, Andres Báez Moreno, Yariv Brauner
Taxing The Digital Economy Post-Beps…Seriously, Andres Báez Moreno, Yariv Brauner
UF Law Faculty Publications
For years the advent of the digital economy has left countries stumped in their attempt to tax income earned by foreign firms without physical presence within their jurisdiction. International organizations and their member countries have failed in their attempts to tweak the rules of the international tax regime and address these challenges presented by the digital economy. This article argues that such conservative approach could not work, and fundamental reform is inevitable. The article proposes a withholding tax solution, explaining its merits and demonstrating its superiority over alternative reforms proposed to date.