An Analysis of Actions of the OECD Action Plan on BEPS in the Digital Economy

Bachelor Thesis , 2016 , 57 Pages

Communications - Multimedia, Internet, New Technologies

This thesis investigates the various actions presented in the “Action Plan on Base Erosion and Profit Shifting” and their applicability to companies operating in the digital economy. Besides the actions stated in the Organisation for Economic Co-operation and Development’s (OECD) Action Plan other measures against BEPS that can be found in recent literature are analysed and compared.

Furthermore, it is examined whether these actions are suitable for preventing tax evasion of ebusinesses acting on a cross-border level. Both, indirect and direct taxation, as well as the concept of permanent establishment (PE) in the context of the digital economy are considered and analysed in this paper. The paper focuses mainly on the taxation of cross-border business transactions in the context of e-business.

However, the thesis does not examine the situations of specific countries but primarily utilises a general view on the actions without regional limitations. Taxation of bricks and mortar businesses are not specifically considered, though, parallels to the digital economy may be drawn throughout the thesis.

Table of Contents

List of Abbreviations

1. Introduction
1.1. Problem Definition
1.2. Aims and Non-Aims
1.3. Methodology and Structure
1.4. Definitions of Technical Terms
1.4.1. Direct and Indirect Taxes
1.4.2. Permanent Establishment

2. Attributes and Growth of the Digital Economy
2.1. Development and Impact on the Business Environment
2.2. Different Business and Revenue Models in the Digital Economy
2.2.1. E-Commerce
2.2.2. Application Stores
2.2.3. Cloud Computing
2.2.4. Online Advertising
2.3. Overview on the Principal Characteristics of the Digital Economy

3. Concepts of the International Taxation System
3.1. The Role of the OECD in International Taxation
3.2. Principles of International Taxation
3.3. Double Tax Treaties and Taxation of Cross-Border Transactions

4. Challenges of Taxing the Digital Economy
4.1. The Role of PEs in the Digital Economy
4.2. BEPS in Terms of Direct Taxation
4.3. BEPS Relating to Indirect Taxation

5. Evaluation of Countermeasures
5.1. Methods Against Artificial PE Avoidance
5.2. Amendments to Transfer Pricing Rules
5.3. Measures Against Artificially Positioning Income in Low-Tax Jurisdictions
5.4. Actions for the Prevention of BEPS with Regard to Indirect Taxation

6. Discussion

7. Conclusion and Future Outlook

8. References

• Author: Melanie Keller (Author)
• Publication Year: 2016
• Pages: 57
• Catalog Number: V352842
• ISBN (eBook): 9783668392977
• ISBN (Book): 9783668392984
• Language: English
• Tags: analysis, actions, oecd, action, plan, beps, digital, economy