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Through the Looking Glass : Computer Servers and E-commerce Profit Attribution
| Content Provider | Semantic Scholar |
|---|---|
| Author | Cockfield, Arthur J. |
| Copyright Year | 2004 |
| Abstract | [1] This report discusses, from a tax policy perspective, the problems associated with permitting countries to tax profits attributable to computer servers (that is, computers that have been networked to the Internet). Part I discusses reform efforts where OECD member states agreed that, under traditional international tax principles, a server can constitute a permanent establishment in some circumstances. Part II describes how the OECD has attempted to constrain abusive tax planning through proposed profit attribution rules with respect to e-commerce profits and servers. Part III argues that the "one-two" punch of these reform efforts will result in a test that emphasizes economic presence instead of physical presence, a significant departure from traditional international tax principles. |
| File Format | PDF HTM / HTML |
| Alternate Webpage(s) | http://post.queensu.ca/~ac24/TNArticle.pdf |
| Language | English |
| Access Restriction | Open |
| Content Type | Text |
| Resource Type | Article |
