Digital technology allows businesses to operate in a country without a physical presence, which poses challenges for traditional taxation. The digital debate focuses on direct taxation and the creation of new taxing rights arising from the tax claims of market jurisdictions on income obtained by foreign digital suppliers conducting business therein without any physical presence.
Tax Theory Applied to the Digital Economy analyzes the tax-disruptive aspects of digital business models and reviews current tax initiatives in light of traditional tax theory principles. The analysis concludes that market countries' tax claims are unsubstantiated and contravene the most basic foundations of tax theory, giving rise to a series of legal, economic, tax policy, and tax administration issues that policy makers cannot overlook.
The authors propose establishing a digital data tax (DDT) that is a license-type consumption tax, rather than an income tax, on the international supply of internet bandwidth to access digital markets. The DDT can be applied either globally or unilaterally, and could become a significant source of tax revenues for market jurisdictions. It is aligned with tax principles and it does not conflict with other tax initiatives: the DDT taxes foreign digital companies as consumers, while income tax proposals tax them as suppliers. The authors also propose creating a new global internet tax agency (GITA) under the auspices of the United Nations that would provide a neutral forum for political discussion and technical assistance in the area of digital taxation. The digital economy is a global phenomenon that requires a global solution: the creation of global taxing mechanisms and global institutions that provide technical assistance and support for successful global implementation.
The book explains difficult technical concepts in plain language and contributes to the digital tax debate in a way that can be understood by anyone. Such understanding is essential to obtaining global support, achieving tax compliance, and fostering multilateral tax cooperation.
"The book provides a solid account and well-taken critique of many recent proposals that have been floating around with respect to international income taxation and that seem to have been navigating through these difficult waters without making use of some basic guidelines to good tax policy. The book correctly suggests that from a principled perspective, much of what has been said about this issue is perhaps little more than an attempt to dress up what is in some respects a simple (unprincipled?) 'tax grab.' And, most importantly, the book presents an interesting alternative approach: the digital data tax."
- RICHARD BIRD, Professor emeritus of economics Rotman School of Management
"The book is ahead of the curve. Frequently, we lament that the tax administration lags behind the private sector. This is the way to jump out front. This proposal changes the tax administration into a Tech and Data Administration. As Larry Lessig observed, Code is law. Making the tax system digital is to regulate the tax that is collected and remitted. This approach will merge value added tax and income tax compliance in the not-too-distant future. This is the future."
- RICHARD AINSWORTH, Adjunct professor of law New York University
"The authors provide a set of solid justifications for the innovative design of a digital data tax (DDT), stating that it is an indirect tax (not a direct income tax), which would offer the 'best compromise' out of all current digital taxes and tax initiatives. This is based on the arguments that the proposed tax takes into account not only the interests of both source and residence countries, but also those of digital multinationals; therefore, this is a trade-o that requires a three-way compromise. And this is critically important and highly relevant in the global debate on the highly contentious issues of taxing digital."
- TUAN MINH LE, Lead economist, World Bank