Cloud Computing: Difficulties in Applying Current and Proposed Nexus and Profit Allocation Rules in a Cross-Border Scenario
Journal
Country
European Union; International; OECD
Published Date
Issue
Bulletin for International Taxation 2020 (Volume 74), No. 2
Document
This article discusses the international tax challenges with respect to business profits arising from the digital economy using the cloud computing service model. In particular, it examines issues that arise from the OECD Model Convention (2017) and other OECD documents, the EU Proposal for a Directive on a Significant Digital Presence and the OECD Secretariat Proposal for a “Unified Approach” under Pillar One.