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A Critical Review of Italy’s Digital Services Tax
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resolves10.59403/2b1k88z
The Spanish Digital Services Tax: A Paradigm for the Base Enlargement & Profit Attraction (BEPA) Plan for the Digitalized Economy
resolves10.59403/1msjp5c008
Chapter 8: Comments on the Digital Services Tax: A Panacea or Placebo for the Taxation of the Digital Economy?
resolves10.59403/337z28e
The French Crusade to Tax the Online Advertisement Business: Reflections on the French Google Case and the Newly Introduced Digital Services Tax
resolves10.59403/3w8whew
Pillar 1 of the Inclusive Framework’s Work Programme: The Effect on the Taxation of the Digital Economy and Reallocation of Taxing Rights
resolves10.2139/ssrn.3882142
It’s Time for Pillar 3: A Global Excess Profits Tax for COVID-19 and Beyond
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no DOI — not checkedPhD in Taxation and Professor of Tax Law, University of Trieste. The author can be contacted at dstevanato@units.it.
no DOI — not checkedProposal for a Council Directive on the common system of a digital services tax on revenues resulting from the provision of certain digital services (21 Mar. 2018), COM(2018) 148 final, Primary Sources IBFD [hereinafter DST Proposal].
no DOI — not checkedAlthough the digitized economy is a global phenomenon, its impact on taxation affects affluent European markets in particular. This is due to the fact that digital businesses are mainly headquartered in the United States and, to a lesser extent, in China. Accordingly, these two countries have the ultimate claim to tax as the states of residence. In contrast, European states, previously capital exporting countries in the brick-and-mortar age, are, with regard to digitized business, in a position similar to that of developing countries.
no DOI — not checkedOECD/G20, Addressing the Tax Challenges of the Digital Economy – Action 1: 2015 Final Report , p. 113 et seq. (OECD 2015), Primary Sources IBFD.
no DOI — not checkedProposal for a Council Directive laying down rules relating to the corporate taxation of a significant digital presence (21 Mar. 2018), COM(2018) 147 final, Primary Sources IBFD [hereinafter Significant Digital Presence Proposal].
no DOI — not checkedConsequently, the Significant Digital Presence Proposal is intended to avoid undertakings with a low level of activity being forced to sustain high compliance costs.
no DOI — not checkedIT: Legge [Law] 145, 30 Dec. 2018, GU 302 (2018), art. 1(37) et seq.
no DOI — not checkedIT: Law 160, 27 Dec. 2019, GU 304 (2019), art. 1(678).
no DOI — not checkedThe tax entered into force on 1 Jan. 2020.
no DOI — not checkedSimilarities between the Italian DST and the DST Proposal are noted by A. Perrone, Il percorso (incerto) della cd. web tax italiana, Riv. Dir. Trib. online (30 Aug. 2019) and T. Di Tanno, L’imposta sui servizi digitali si allinea alla proposta di Direttiva UE, 43 Il Fisco 4, p. 327 (2019).
no DOI — not checkedArts. 3 and 8 DST Proposal.
no DOI — not checkedCompare art. 3(7) DST Proposal and art. 1(38) Law 145/2018.
no DOI — not checkedCommission Staff Working Document, Impact Assessment, Accompanying the document Proposal for a Council Directive laying down rules relating to the corporate taxation of a significant digital presence and Proposal for a Council Directive on the common system of a digital services tax on revenues resulting from the provision of certain digital services, p. 74, SWD(2018) 81 final/2 [hereinafter Impact Assessment].
no DOI — not checkedArt. 3(8) DST Proposal deems such revenue to have been derived by the entity providing the service.
no DOI — not checkedArt. 1(678) Law 160/2019, which introduced a new paragraph (37-bis) into art. 1 Law 145/2018.
no DOI — not checkedCompare Recital 13 DST Proposal and art. 1(37-bis)(a)(b) Law 145/2018.
no DOI — not checkedCompare Recital 14 DST Proposal and art. 1(37-bis)(c) Law 145/2018.
no DOI — not checkedCompare Recitals 19-21 DST Proposal and art. 1(37-bis)(d)(e) Law 145/2018.
no DOI — not checkedExplanatory Memorandum, p. 7 DST Proposal.
no DOI — not checkedId., at p. 2.
no DOI — not checkedAs is acknowledged also by the OECD, in OECD/G20, Public Consultation Document: Addressing the Tax Challenges of the Digitalisation of the Economy, 13 February – 6 March 2019 p. 18 (OECD 2019), Primary Sources IBFD: “it could be argued that the value created by the contribution and engagement of users does not constitute value created by the business, and instead constitutes value created by third-parties, that are more akin to suppliers than employees, and are remunerated at arm’s length through the provision of a free service”.
no DOI — not checkedOn the equivalence between a gross-basis tax and a tax on inputs, see OECD/G20, Tax Challenges Arising From Digitalisation – Interim Report 2018: Inclusive Framework on BEPS p. 179 (OECD 2018), Primary Sources IBFD [hereinafter Digitalisation Interim Report]. According to the Association of Italian Joint-Stock Companies (Assonime), Circular No. 19/2018, p. 89, through the EU DST, a profit-share is imputed and charged to the digital undertaking notwithstanding its having been generated by other productive factors, such as user participation and user-generated data. Accordingly, there is a clear similarity between the EU DST and a business tax on gross income, such as the Italian imposta regionale sulle attività produttive (regional tax on productive activities, IRAP), as enacted by IT: Decreto Legislativo [Legislative Decree] 446, 15 Dec. 1997, GU 298 (1997).
no DOI — not checkedOn the role of digital users as providers of raw material (data) to be transformed into valuable information, see Di Tanno, supra n. 11, at p. 327.
no DOI — not checkedThe point is addressed in other approaches to the digitalization issue, such as that envisaged in the OECD, Public Consultation Document: Secretariat Proposal for a “Unified Approach” under Pillar One, 9 October – 12 November 2019 p. 15 (OECD 2019), in which it is acknowledged that non-routine profits generated by groups of multinational enterprises (MNEs) are attributable to numerous activities, including those not linked with the market jurisdiction: “for example, a social media business may generate non-routine profit from its customers’ data and valuable brand, but also from its innovative algorithms and software”.
no DOI — not checkedI. Vacca, Web tax: il vero interrogativo non è “cosa tassare” ma “chi può tassare”, Assonime Position Papers 1/2018, p. 7.
no DOI — not checkedId., at p. 6, where such a classification is affirmed.
no DOI — not checkedSee Testo Unico Delle Imposte Sui Redditi [Income Tax Code], art. 67(lett. l), as approved by IT: Decreto del Presidente della Repubblica [Presidential Decree] 917, 22 Dec. 1986, GU 302 (1986); see also art. 71(2), which lists among the residual category of “other incomes” the difference between the amount received in the fiscal year and the expenses specifically related to the production thereof. That said, it would appear to be difficult to conceive of any costs incurred by the user and specifically associated with the access to digital interfaces.
no DOI — not checkedSuch is the view of, for example, A. Carinci, La fiscalità dell’economia digitale: dalla web tax alla (auspicabile) presa d’atto di nuovi valori da tassare, 43 Il Fisco 47-48, p. 4513 (2019), who even advocates a property tax on the value of data gathered by digital undertakings, but without providing any idea as to how such a value should be determined.
no DOI — not checkedP. 56 Impact Assessment: “The tax would be levied early-on in the value creation process on the provision of a digital service (for example, performing a web search) remunerated by users through the provision of data. In the absence of a monetary compensation for the digital service, the tax would have to be levied on a deemed turnover or profit on the barter transaction: provision of data for access to a digital service. Therefore a deemed monetary value would have to be attributed to data transactions, which is not realistic to implement within a short period of time.”
no DOI — not checkedExplanatory Memorandum, p. 8 DST Proposal.
no DOI — not checkedId., at p. 9.
no DOI — not checkedArt. 4 DST Proposal. The “relevant financial year” is that covered by the last available financial statement issued before the end of the year for which the taxpayer’s status is to be verified. This position should entail that the company is taxable, in a certain tax period, only if the thresholds have been surpassed in the previous financial year.
no DOI — not checkedOn this point, see R. Mason & L. Parada, Digital Battlefront in the Tax Wars, 92 Tax Notes Intl. 12, pp. 1183-1197 (17 Dec. 2018); Simmonds, supra n. 24, at p. 199 et seq.; and Valente, supra n. 24, at p. 219.
no DOI — not checkedSee D. Bunn, The Italian DST Remix, Tax Foundation (23 July 2019), available at https://taxfoundation.org/italy-digital-tax, who points out that the “tax is structured to only apply to large businesses. If a digital business that operates an online marketplace with Italian users is just below the threshold for the DST, the formula does not apply. As soon as the business crosses that threshold, though, it is effectively attributed a 12.5 percent taxable profit margin regardless of the value that is derived from its Italian user base. This last point should be especially concerning for digital companies in Italy that aspire to become global giants. Such a company may be running losses while building its user and customer base, but if it grows to a stage where its revenues are above the threshold, then the DST would kick in and its tax situation could change drastically.”
no DOI — not checkedRecital 24 DST Proposal.
no DOI — not checkedConsolidated Versions of the Treaty on European Union and the Treaty on the Functioning of the European Union (TFEU), art. 18, OJ C115 (2008), Primary Sources IBFD. With regard to the Italian DST, it would then be possible to make the same criticism as is made of the French DST by Mason & Parada, supra n. 39, at p. 647 et seq.
no DOI — not checkedArt. 1(36) Law 145/2018, as amended by Law 160/2019.
no DOI — not checkedAs emphasized by A. Tomassini & A. Di Dio, Web tax sui servizi digitali: soluzione transitoria in attesa delle decisioni dell’Ocse, 42 Corr. Trib. 4, p. 346 (2019).
no DOI — not checkedExplanatory Memorandum, p. 11 DST Proposal: “Depending on where the taxable person is established, the scenarios where DST liability may arise can involve a taxable person established in a non-Union jurisdiction having to pay DST in a Member State, a taxable person established in a Member State having to pay DST in another Member State, or a taxable person established in a Member State having to pay DST in that same Member State.”
no DOI — not checkedSee p. 57 Impact Assessment: “To comply with the existing legal framework, the tax would need to apply to resident and non-resident companies alike, as well as to domestic and cross-border transactions. The equal treatment of residents and non-residents is needed to comply with the free movement of services case law of the Court of Justice which found that it is discriminatory to apply a specific tax to non-residents, if the comparable activity or income of resident taxpayers is not taxed by an analogous tax.”
no DOI — not checkedCompare Mason & Parada, supra n. 39, at p. 1192 et seq. The same concern is expressed in G. Kofler & J. Sinnig, Equalization Taxes and the EU’s “Digital Services Tax”, in Tax and the Digital Economy. Challenges and Proposals for Reform p. 130 (W. Haslehner et al. eds., Wolters Kluwer 2019) and Becker & Englisch, supra n. 24.
no DOI — not checkedArt. 1(25-bis) and (42) Law 145/2018, as amended by Law 160/2019. The tax applies to revenues obtained throughout the year, and must be paid in its entirety by 16 February of the following calendar year.
no DOI — not checkedUS: Trade Act of 1974.
no DOI — not checkedAccording to the Office of the United States Trade Representative (USTR), USTR-2020-0022, Initiation of Section 201 Investigations of Digital Services Taxes (2 June 2020), Italy’s DST, among others, is under investigation.
no DOI — not checkedExplanatory Memorandum, p. 11 DST Proposal.
no DOI — not checkedAccordingly, no relevance is assigned to the user’s residence.
no DOI — not checkedArt. 5(5) DST Proposal.
no DOI — not checkedId., at art. 5(1-2). See also Explanatory Memorandum, pp. 11-12 DST Proposal.
no DOI — not checkedExplanatory Memorandum, p. 11 DST Proposal: “the user involvement in the digital activities of a company [is what generates] the value for that company, which may not necessarily entail a payment from the users’ side (e.g. viewers of advertising on a digital interface) … Therefore, ... the Member State where the user is located [is] the one with taxing rights in respect of DST, regardless of whether the user has contributed in money to the generation of revenue for the company.”
no DOI — not checkedA previous version of the levy, enacted by IT: Law 27 of December 2017, No. 205, GU 302 (2017), paras. 1011 et seq., provided for a 3% tax on the revenue stemming from services rendered to undertakings located in Italy, to be withheld at source by the customer. The tax would have applied only above a threshold of 3,000 transactions in the fiscal year. The services involved were those carried out through electronic devices, of an automatic nature, relying on information technology and with minimal human intervention, on the assumption of a value generation different from those entailed by traditional transactions. The digital services affected by the tax were to be determined in more detail by a Ministry decree, but the levy was repealed before it came into force.
no DOI — not checkedSuch distinction is overlooked by Carinci, supra n. 33, who deems the Italian DST to apply to revenues stemming from services provided to end-users located in Italy. The fundamental difference between a DST and a destination-based tax is highlighted, inter alia, by W. Cui, The Digital Services Tax: A Conceptual Defense, Working Paper, p. 9, available at https://ssrn.com/abstract=3273641 (accessed 14 June 2020).
no DOI — not checkedSee Di Tanno, supra n. 11, at p. 332 et seq. and Tomassini & Di Dio, supra n. 44, at p. 349.
no DOI — not checkedArt. 5(3)(c) DST Proposal.
no DOI — not checkedId., at art. 5(3).
no DOI — not checkedExplanatory Memorandum, pp. 11-12 DST Proposal: “Taxing rights over the revenues of the business making available the interface are allocated to a Member State where the users concluding underlying transactions are located, irrespective of whether the users are the sellers of the underlying goods or services or the buyers. This is because both of them generate value for the multi-sided digital interface through their participation, given that the role of the interface is to match supply and demand.” According to the USTR, supra n. 51, at p. 28, “this rule would result in revenues from the same transaction being covered twice where the buyer and seller were located in different EU members”.
no DOI — not checkedArt. 5(3)(b) DST Proposal.
no DOI — not checkedBy contrast, the Italian law is in keeping with the DST Proposal with regard to intermediation services compensated through periodic payments. In such cases, the allocation key is the number of users holding an account which was opened using a device in the Member State. See art. 1(40-ter)(b)(2) Law 145/2018.
no DOI — not checkedArt. 5(4)(a) DST Proposal.
no DOI — not checkedFor instance, if an Italian resident buyer concludes the transaction using a digital device during a visit to a different Member State, and asks for goods to be delivered in Italy, both the Italian DST and the other Member State’s DST – in compliance with the DST Proposal – would apply to the same revenue.
no DOI — not checkedArt. 5(3)(c) DST Proposal.
no DOI — not checkedSee G. Colombaioni, Italy Unilaterally Implements the European Commission’s Digital Service Tax Proposal, Riv. Dir. Trib. online (21 Feb. 2019), who emphasizes that “the legislation determines the territoriality of the taxable revenues on the basis of the location and number of users without any reference to the number of uses. Nothing seems to be provided if, for example, a user moves outside of Italy and accesses the digital interface while in different countries during the taxable year. In addition, in relation to certain taxable services … it may be objected that, from the perspective of the rationale of the tax, the number of uses might have been a better allocation key.”
no DOI — not checkedRecital 29 DST Proposal.
no DOI — not checkedArt. 1(36) Law 145/2018. Non-resident taxpayers without a permanent establishment in Italy should file a request to the Revenue Agency to be identified for the purpose of the DST.
no DOI — not checkedThe tax must be paid before 16 February. In the DST Proposal, the deadline for filing the tax return is stricter, i.e. 30 working days following the end of the tax period covered by the return. See art. 14 DST Proposal.
no DOI — not checkedThis opinion is shared by F. Pedrotti, Prime osservazioni in merito all’abrogata imposta sulle transazioni digitali e all’imposta sui servizi digitali introdotta dalla L. 30 dicembre 2018, n. 145, 29 Riv. Dir. Trib. 1, I, p. 110 et seq. (2019). On this topic, see also X. Oberson, Taxing Robots: Helping the Economy to Adapt to the Use of Artificial Intelligence ch. 7 (Edward Elgar 2019), for whom DSTs as envisaged by the European Commission take the form of excise taxes on social media and sales of digital services, with the purpose of equalizing the profits of local and foreign digital suppliers of such services.
no DOI — not checkedSee A. Uricchio, Robot tax: Modelli di prelievo e prospettive di riforma, 171 Giur. It. 7, p. 1757 (2019). Similarly, see A. Perrone, L’equa tassazione delle multinazionali in Europa: imposizione sul digitale o regole comuni per determinare gli imponibili?, 8 Riv. Trim. Dir. Trib. 1, p. 87 et seq. (2019), who frames the DST as an indirect tax on value creation.
no DOI — not checkedSee Simmonds, supra n. 24, at p. 195 et seq.
no DOI — not checkedP. 57 Impact Assessment: “alleviating double taxation by crediting corporate tax already paid against the new tax or vice versa is not a feasible option. … First, crediting the new tax (an indirect tax) against corporate income tax (a direct tax) or vice versa would compromise the legal nature of the tax and impact double tax conventions. Second, the possibility to credit corporate income tax (or against corporate income tax) would in practice only be feasible if a company is established or has an existing permanent establishment in a Member State. If as result only those businesses not established in a Member State, or without a permanent establishment in that Member State, would be taxed for their digital services in that Member State, the new tax could be seen as a de facto restriction on the freedom to provide services within the EU.” See also USTR, supra n. 51, at p. 48: “Because the DST is levied on revenues rather than income, it is very likely foreign companies will not be entitled to a credit in their home jurisdiction. The reduced ability to offset the DST against other taxes places foreign companies at a disadvantage, as their overall tax burden becomes higher.”
no DOI — not checkedAccording to Assonime, supra n. 27, at p. 82, the practical difficulty in transferring the burden is exacerbated by the design of the EU DST as a three-sided tax, in which digital undertakings, users of digital interfaces and customers who pay for the services could be located in different states, thereby making it difficult to transfer the tax burden to clients.
no DOI — not checkedAs sketched almost two centuries ago by J.S. Mill, The Principles of Political Economy bk. 5, ch. 3 (J.W. Parker 1848): “a direct tax is one which is demanded from the very persons who, it is intended or desired, should pay it. Indirect taxes are those which are demanded from one person in the expectation and intention that he shall indemnify himself at the expense of another”.
no DOI — not checkedSee also Kofler & Sinnig, supra n. 47, at p. 112.
no DOI — not checkedExplanatory Memorandum, p. 5 DST Proposal. An analogous doubt is raised by Colombaioni, supra n. 73, according to whom, in spite of its classification as an indirect tax in the EU DST Proposal, “there are sound arguments pointing towards the opposite direction, such as the fact that it has been drafted in order to have an effect equivalent to an income tax, both in terms of tax burden and terms of the persons bearing that burden (the taxpayers)”.
no DOI — not checkedSee also Tomassini & Di Dio, supra n. 44, at p. 349; Di Tanno, supra n. 11, at p. 332; and Colombaioni, supra n. 73.
no DOI — not checkedRecital 2 DST Proposal.
no DOI — not checkedOn this point, see USTR, supra n. 51, at p. 56 et seq.: “due to its application to revenue not income, the DST contravenes the tax policy principle of avoiding double taxation. Avoiding double taxation – that is, preventing the same income being taxed twice – is a fundamental principle of the international tax system. … Revenue taxes tend to result in double taxation, and the DST is no exception. The DST ‘creates an additional layer of tax on top of already-existing corporate income taxes … and thereby creates double taxation’. Specifically, if a company covered by the DST is profitable, the money associated with providing the covered services in France will be taxed twice – once as ‘revenue’ under the DST and once as ‘income’ under the corporate income tax of the country where the company pays income tax on income associated with the services covered by the DST. This is because it is unlikely that the country in which the company is resident or operates will exclude revenues associated with the DST from its tax base or otherwise provide a credit or deduction for any DST amount paid.”
no DOI — not checkedRecital 27 DST Proposal.
no DOI — not checkedAs seen in section 8., although DSTs are taxes on gross revenues, rather than on net income, they are aimed at targeting, in a quite rough and indirect way, profits that are allegedly untaxed where value is supposed to be created. According to Martín Jiménez, supra n. 25, at sec. 3.4., unilateral measures enacted by countries with the goal of capturing value created in their market by users and clients that could not be taxed within the current income tax treaties, such as the DST Proposal and the like, “represent new forms of income taxes, regardless of their name, that are hardly compatible with tax treaties that follow the OECD Model”.
no DOI — not checkedSee Assonime, supra n. 27, at p. 89, who considers the EU DST to be a peculiar indirect tax in which gross revenues are a proxy of value created by user participation to digital undertakings. According to this opinion, the EU DST mimics the economic effects that would arise introducing a tax on net profits, thereby making the assumption that a 3% tax on gross revenues is roughly equal to the income taxes that digital undertakings should have paid on the huge net profits they derive. This situation means, as noted by Bunn, supra n. 40, that “a 3 percent tax on revenues works as a strange substitute for standard business taxation. Italy has a statutory corporate tax rate of 24 percent. If a business has €10 of taxable income in Italy, it would owe €2.40 in income tax, assuming the business is taxed at the statutory rate. However, if that business does not owe corporate income tax but is instead subject to the DST, it would pay tax on its revenue rather than its income. If the business has revenues from digital services connected to Italian users of €100, then the DST liability would be €3. If the business subject to corporate income tax has a profit margin of 12.5 percent, the corporate tax and DST liability would be equal (24 percent of €12.5 = €3 and 3 percent of €100 = €3). One way to think about this analysis is that the Italian proposal uses a formulaic approach to tax digital companies. This is instead of doing the difficult work of identifying the value specifically attributable to Italian users of digital services and separating that from the value created by businesses in developing software, building and managing servers, and acquiring advertising customers. The Italian approach is to assume that digital companies have a 12.5 percent profit margin on their services in Italy, and that the entire 12.5 percent profit margin should be taxed in Italy.”
no DOI — not checkedRisks of overtaxation entailed by interim measures, such as equalization levies, are noted also by the OECD at OECD/G20, Digitalisation Interim Report, supra n. 26, at p. 179: “In order to comply with its international obligations, a country may be required to apply the tax to both residents and non-residents, and to limit any credit mechanism against other taxes. This may create issues of over-taxation (for instance, payments for certain e-services may be subject to both an interim measure and corporate income tax), and run counter to the underlying narrative for the introduction of the tax, which is to target supplies of cross border digital services that are not subject to income taxation in the market jurisdiction under existing rules …” and at p. 187: “Where an interim measure takes the form of an excise tax on the gross amount for the supply it has the potential to result in economic double taxation. As noted above economic double taxation may arise due to the fact that the excise tax is applied to both residents and non-residents with no ability to credit the tax against corporate income tax levied on the same payment. This outcome may appear counter-intuitive given that a key driver for an interim measure is the ease with which a non-resident can supply e-services in the taxing jurisdiction without having any taxable presence.” The risk of double taxation is emphasized again by Kofler & Sinnig, supra n. 47, at p. 135.
no DOI — not checkedReferences to the DST as a “temporary measure” may be found in Recitals 6-7 DST Proposal and in Explanatory Memorandum, pp. 2-3 DST Proposal, as well as in (the concurrent) Explanatory Memorandum, p. 4 Significant Digital Presence Proposal, which makes clear that the DST is an interim solution: “The DST should apply on a temporary basis until a comprehensive solution is in place.” The temporary character of interim measures is a feature that is strongly recommended by OECD/G20, Digitalisation Interim Report, supra n. 26, at p. 184.
no DOI — not checkedSignificant Digital Presence Proposal.
no DOI — not checkedArt. 1(49-bis) Law 145/2018: “Paragraphs 35 to 49 of article 1 of the Law of 30 December 2018, No. 145, will be repealed upon the entrance into force of the provisions which will stem from agreements signed at international level with regards to the taxation of digital economy”. (Author’s unofficial translation)
no DOI — not checkedId.
no DOI — not checkedFor further discussion of the topic, see Stevanato, supra n. 39.
no DOI — not checkedOn the excess profits taxes that entered into force in the United Kingdom and in the United States during the world wars of the 20th century, see R.M. Haig, British Experience with Excess Profits Tax, Am. Econ. Rev. 10, Suppl. (1920)
no DOI — not checkedT.S. Adams, Federal Taxes upon Income and Excess Profits, Am. Econ. Rev., suppl., pp. 18-35 (1918)
no DOI — not checkedand H.M. Groves, Postwar Taxation and Economic Progress (McGraw-Hill 1946). Italy faced a similar experience with the claw-back of the profits realized under the fascist regime (see IT: Decreto Legislativo Luogotenenziale [Legislative Decree] No. 134 of 26 Mar. 1946, GU No. 82 (1946)).
no DOI — not checkedOECD, Tax and Fiscal Policy in Response to the Coronavirus Crisis p. 43 (OECD 2020).
no DOI — not checkedOECD, Public Consultation Document: Secretariat Proposal for a “Unified Approach” under Pillar One, 9 October – 12 November 2019 (OECD 2019); OECD, Global Anti-Base Erosion Proposal (“GloBE”) Pillar Two, 8 November – 2 December 2019 (OECD 2019).
no DOI — not checkedCommunication from the Commission to the European Parliament, the European Council, the Council, the European Economic and Social Committee and the Committee of the Regions. The EU budget powering the recovery plan for Europe (27 May 2020), COM(2020) 442 final, p. 15: “Companies that draw huge benefits from the EU single market and will survive the crisis, also thanks to direct and indirect EU and national support, could contribute to rebuilding it in the recovery phase. This could include an own resource based on operations of enterprises which, depending on its design, could yield around EUR 10 billion annually.”
no DOI — not checkedSimilar concerns are expressed, with regard to the Italian DST, by Bunn, supra n. 40: “the Italian approach is to assume that digital companies have a 12.5 percent profit margin on their services in Italy, and that the entire 12.5 percent profit margin should be taxed in Italy. A problem with such a formulaic approach is that not all businesses fit the formula. The formula does not recognize that some digital companies may effectively be losing money on their Italian user base in some years or that they may be less profitable than the formula suggests.”
no DOI — not checkedAfter all, in the last few years, some European countries have already experienced turnover-based taxes. See Mason & Parada, supra n. 39 and Stevanato, supra n. 39.
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