Introduction
“Profits should be taxed where economic activities deriving the profits are performed and where value is created”1. The relationship between taxation and technological developments have always been dynamic and complex. The internet represents the greatest technological revolution since the industrial revolution. Data show that there is approximately $xxx billion trade occurring through e-commerce, with xxx billion internet users and xx billion domain names as of 20142 and this number keeps changing every second. This paper takes a look at the current tax issues relating to e-commerce and profit shifting and also the new OECD framework aimed at addressing these challenges.
Tax Issues
Governments and tax authorities face the same problems whilst trying to tax digital or online businesses: “what is the appropriate nexus that permits the application of tax jurisdiction over cross-border sales?”
Concerns have been expressed that e-commerce could result in base erosion and profit shifting [BEPS]. Consumption taxes are levied on the principle of taxation at the place of consumption and according to rates set in individual country or state. E-commerce, however, has the potential to undermine the application of domestic and national tax rules. Tax planning for an e-business differs from tax planning for a traditional bricks and mortar company. In the past, generation of income depended on the physical presence of assets and activities. This physical presence, permanent
One of the most important periods of history was the Industrial Revolution. Many of the inventions made during this time make our everyday life possible. The Industrial Revolution was the period of time during the 18th and 19th centuries when new technological advancements changed the face of industry. These changes had a lasting impact on the economies of the world and the lives of average people. There were hundreds of inventions during this time period. These inventions resulted in advances in new energy sources, communication and transport.
Also I looked into the regulations on e-commerce and according to Renee L Giachino, “attempts to regulate the Internet can cause national and international conflict and criticism. Individual attempts by states and countries to place burdensome restrictions on the free flow of trade over the Internet should be avoided in favor of unfettered growth of the many borderless opportunities and advantages that e-commerce
The Industrial Revolution had become an influential event that has occurred during the early eighteenth century and continued throughout the civil war. All of the new inventions created has helped many individuals be able to complete their jobs more efficiently. The advance equipment lead the factories to produce more products in a quicker timespan. This factor brought a large amount of goods to the people at a faster rate. Therefore, all of the technological advancements and innovations affected many aspects of American lives. The effects of industrialization in the United States impacted immigration, commercial and industrial development, railroads, organized labor and agriculture.
There is also confusion regarding what is Constitutionally acceptable in the online marketplace. Many consumers and businesses believed that taxing products over the Internet was not allowed. . This misconception was cleared up in infamous Quill Corp. v. North Dakota case, which created the “nexus” law. This case has greatly effected the taxation of Internet sales. It stated that there must be a large physical presence of a company in a state for that state to lawfully require the company to collect taxes inside the state (Andes & Atkinson, 2013). With the growth of the Internet, many of these misconceptions are attempting to be understood through various forms of legislation.
Q: The government is foregoing a lot of revenue by not taxing products bought from the internet from overseas.
The engine of the Internet economy has countries scrambling to enact popular start-up markets, ease e-commerce taxation, and climates conductive to foreign investments in online media properties. As an example, Canada has the highest Internet usage in the world, but an unfavorable tax regime and a lack of start-up capital are causing the country to fall behind the United States in the e-commerce economy. Canadian taxes, government regulations, and capital markets created a slow growth of Internet business. Furthermore, this has eased the distribution and duplication of information and products from e-commerce sales across borders. Serious issues such as copyright, encryption, trademark, and regulation of currencies being raised, therefore are forcing the U.S. Federal Trade Commission and the Treasury Department to issue warnings against proliferation of commercial scamming, Internet fraud, and potential money laundering by unscrupulous agents operating over the
The Industrial Revolution was called a revolution because new technologies dramatically changed American society and its economy in ways that had never before been experienced. Before the Industrial Revolution, manufacturing was done in what are called cottage industries today. Experienced and skilled people worked in their own homes, using their hands or hand tools and very basic machinery, to produce hand-made goods of very high quality. The Industrial Revolution changed all that. New machines with interchangeable parts and new manufacturing methods such as the Bessemer Process were developed to make manufacturing quicker, easier, and more profitable. Forms of power such as steam and electricity were harnessed and put to use in new, efficient ways. These new technologies changed people’s lives in favorable and unfavorable ways.
The industrial revolution began in the late 18th century and was seen as a process of denaturalization (2). As society began to use synthetic materials, wood which was the prime material at the time lost its universal functions. The shortage of wood and the high prices of grain catalyzed the replacement of horsepower by mechanical power. Various improvements in steam technology eventually led to the use of the steam engine as a locomotive. The development of the railroad as a national mode of transportation brought changes in the lives of the Europeans. The transition from using stagecoach to using the railroad as a means of transportation completed the detachment from nature. All of a sudden, the same amount of time permitted one to cover
22. The technological developments during the industrial revolution that enabled people to build factories were trains.
Having confined to limited natural resources and a restricted environment, any activity somewhere on the earth will have its impacts all around sooner or later. Nature had been established an equilibrium, compensating for negative individual impacts of living kinds, may be presenting the best conditions for all, till the near past. However, human activities, due to their intensity, frequency, influence and as being mostly out of natural processes establishing the equilibrium, have been forcing this equilibrium seriously since the industrial revolution.
Starting in 18th century Great Britain the Industrial Revolution sparked a change in industry that is still present today. The Industrial Revolution was a great blessing to society, with innovations in consumer goods, medicine, and sanitation; the revolution changed the course of history for the better.
Have you ever purchased any product on the Internet, used the Internet to collect information or data, or played computer games on the Internet? You must agree that it is fast, easy, and enjoyable. The Internet has been a part of our daily life for several years now. In addition, in the business world, a new business model, E-business and E-commerce, has appeared for several years. According to Ali, there are two main types of E-commerce: B2B and B2C (2000). One is business to business (B2B). This means that enterprises use the Internet to transact or trade between business operations and their partners. Another is business to consumer (B2C). In other words, enterprises provide products, support good, and services to the customers on the
Throughout the country, states are not collecting some or any taxes on online transactions. This debate has been brought to Congress, state, and local governments as to whether taxes should be imposed on online transactions as well as who should standardize online taxing. Research shows that the estimated revenue losses in excess of $60 billion alone from online transactions. This number is only to grow with increased use of ecommerce. (McClure 2000)
revenues via e-commerce in the next two to three years (Richter, 48). The core of e-
1. Abstract 2. International tax law & its sources 3. Brief history of International Tax Law 4. Who gets the pie? 5. Arm 's length principle : Cornerstone of International Tax Law 6. Transfer pricing methods 7. Problems with of source taxation of MNE 's 8. Internet & e-commerce : Achilles heel of current International taxation regime? 9. Formulary Apportionment (FA) 10. Existing uses of Formulary Apportionment systems in the world 11. Developing countries & Formulary Apportionment 12. Critique of Formulary Apportionment 13. Transfer pricing and Formulary Apportionment : One continuum 14. Conclusion 15. Acknowledgements 16. References