The EC’s communication on digital taxation

The European Commission (EC) has set out its plans for ‘a fair and efficient tax system in the EU for the digital single market’ in a communication to the EU Parliament and the Council. The EC believes the entire international tax framework needs to be reformed and that the OECD’s base erosion and profit shifting (BEPS) project did not go far enough in achieving this – neither through the Action 1 review of the so-called ‘digital economy’ the changes to the definition of permanent establishment (PE) or amendments to the OECD Transfer Pricing (TP) Guidelines. The EC believes this inadequacy can be dealt with through the introduction of the common consolidated corporate tax base (CCCTB) and the extension of the PE concept to ‘virtual’ PEs. The EC is seemingly prepared to wait for the OECD’s impending interim report on the taxation of the digital economy to be released in...