Independent expertise for the international tax challenges of the 21st century
IBFD - Independent expertise for the international tax challenges of the 21st century
The old international tax principles and the new economic environment
International tax principles were established in the first decades of the 20th century following the works of the League of Nations and the International Chamber of Commerce . The issue is whether these principles can still rule the international tax relationships in the 21st century , in the framework of an economy where services and intangible assets and , especially , information are the key valuable goods which are the object of cross-border transactions . Further , in the last years we have moved , in many cases , from the aim of eliminating double taxation to the need of assuring that income is taxed at least in a fair manner in one jurisdiction ( i . e . avoiding non-taxation ). Finally , the economic crisis of 2008 has revealed the urgent need to search for solutions to the deficiencies of the system and , in some cases , has also changed the standpoint under which those solutions have to be found .
The main issues and responses
Permanent establishments . In many cases , there is a divorce between the place where the business profits of an entity are taxed and the effective place where the economic activities are carried out and the profits are obtained . There seems to be a consensus between all the parties concerned that the traditional concept of permanent establishment ( PE ) would need to be reviewed and extended to cover also situations where there is a
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