Despite its proliferation and wide acceptance, the Arm’s Length principle, cornerstone of the transfer pricing analysis for tax purposes, has had followers and opponents. Its application has been evolving in line with the evolution of the business models of multinational companies. There has been significant progress as a result of…
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Tax informality is part of the so-called hidden, informal, submerged, underground, black economy, etc., which is defined as all the legal production of goods and services oriented to the market that are deliberately removed from government control (Schneider 2010), both to avoid the tax burden and Social Security contributions, as…
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Increasingly, Tax Administrations (TAs) use new ICTs to be more effective and efficient in their management, and the digitalization process has accelerated exponentially in the current circumstances. Within this new technology, Artificial Intelligence (AI) presents multiple benefits for TAs, since it transforms data into a knowledge and impact asset for…
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Digital economy and taxation The digital economy, which is the new economy and not a part of it, challenges the principles that underpinned international taxation in recent decades, with its particularities: The principles of taxation, which are now obsolete to deal with the new business models of digital companies and…
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The current crisis that threatens life and social coexistence incited me to think about the effects that man-made technological tools produce on the socio-economic conditions of the pandemic that humanity suffers. Paulo Coelho wrote that a hammer would make no sense if there were no nails to hit in the…
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We intend to analyze the tax aspects of the digital economy based on the principle embodied in Action 1 of BEPS, concerning the digital economy, to achieve ” … a better alignment between the localization of taxable profits and the localization of economic activities and the creation of value”. In…
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