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International Taxation In An Era Of Digital Disruption: Analyzing The Current Debate, Itai Grinberg
International Taxation In An Era Of Digital Disruption: Analyzing The Current Debate, Itai Grinberg
Georgetown Law Faculty Publications and Other Works
The “taxation of the digital economy” is currently at the top of the global international tax policymaking agenda. A core claim some European governments are advancing is that user data or user participation in the digital economy justifies a gross tax on digital receipts, new profit attribution criteria, or a special formulary apportionment factor in a future formulary regime targeted specifically at the “digital economy.” Just a couple years ago the OECD undertook an evaluation of whether the digital economy can (or should) be “ring-fenced” as part of the BEPS project, and concluded that it neither can be nor should …
A Constructive U.S. Counter To Eu State Aid Cases, Itai Grinberg
A Constructive U.S. Counter To Eu State Aid Cases, Itai Grinberg
Georgetown Law Faculty Publications and Other Works
U.S. Treasury officials and members of Congress from both parties have expressed concern that the European Commission’s current state aid investigations are disproportionately targeting U.S.-based multinational enterprises. At the same time, a Treasury official recently suggested in congressional testimony that there are limits to what Treasury can do beyond strongly expressing its concerns to the commission. In that testimony, Treasury’s representative hinted at two specific pressure points: whether the state aid investigations could undermine U.S. tax treaties with EU member states; and whether any assessments paid by the foreign subsidiaries of U.S. MNEs as a result of state aid investigations …