Taxing the Digital Economy Post BEPS . . . Seriously Articles uri icon

publication date

  • September 2019

start page

  • 121

end page

  • 188

issue

  • 1

volume

  • 58

International Standard Serial Number (ISSN)

  • 0010-1931

Electronic International Standard Serial Number (EISSN)

  • 2159-1814

abstract

  • For years, the advent of the digital economy has leftcountries stumped in their attempt to tax incomeearned by foreign firms without physical presencewithin their jurisdiction. International organizationsand their member countries have failed in their attemptsto tweak the rules of the international tax regimeand address the challenges presented by thedigital economy. This Article argues that such a conservativeapproach could not work and fundamentalreform is inevitable. The Article proposes a withholdingtax solution, explaining its merits and demonstratingits superiority over alternative reforms proposedto date.