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Taxation of Digital Activities, Digitalization of Taxation

Anne-Valérie ATTIAS ASSOULINE * Avocate, Associée, PwC Société d'Avocats.
Guillaume GLON ** Avocat, Associé, PwC Société d'Avocats. Contact : guillaume.glon@pwcavocats.com.


The current set of rules governing the taxation of business income was conceived in the 1920s, in the heydays of the brick and mortar economy, when multinational enterprises created value primarily through low mobile production factors such as labor and tangible assets. Today, because of the booming of the digital economy, the secular connection between the physical presence of a company, through its human and material resources, and the markets on which it makes its sales, fades away. In addition, the current tax system is not properly apprehensive of the new value drivers in a digital and global world, such as the key role of intangible assets, know-how, the ability to exploit data. These highly mobile assets can be located anywhere and notably outside the countries where the customers are located. In this article, we discuss the limits of the current tax system, the possible solutions and the practical difficulties that make it particularly difficult to reach a consensus on a global solution. The digitization of the economy also results in massive changes in the relationship between taxpayers and tax administrations. The later now dispose of increasingly sophisticated tools to collect and control taxes and to fight against tax evasion. We briefly mention this new world, which is still largely unexplored.


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