The speed and scale of the changes caused by digitalisation have had implications for the UK tax system especially in respect of corporation tax, where the development of certain business models has challenged the understanding of how and where companies create value and ultimately how that value is taxed.

At the Autumn Budget 2017 the government set out its initial position on the issue underlining the principle which underpins the international corporate tax system that the profits of a business should be taxed in the countries in which value is created. The government were concerned that this principal was being challenged by certain digital businesses and the paper published in November 2017 sought to address that question, by assessing three possible challenges that have been put forward: Read More

We’ve been in the “digital economy” for some time, yet it continues to evolve with new business activities and ways of living. And, we see “old economy” businesses, like Ford Motor, move more into the new economy.

I define the digital economy from the perspective of how people and businesses engage in it:

• Transacting business with virtual currencies, such as Bitcoin;

• Providing digital goods and services; and

• Transacting business enhanced by the Internet, such as finding customers, including Read More

In a speech last week ATO’s Mark Konza, Deputy Commissioner – International, gave an insight into the ATO’s activities in responding to a number of the OECD’s post Cairns G20 Minister’s Conference BEPS Action Plan items.

Deputy Commissioner Konza put particular emphasis on the ATO’s strategy in connection with “Action Item 1: address the tax challenges of the digital economy”. Commenting on the ATO’s work on this aspect he said-

“The broader digital economy is also being addressed through our four-year dedicated compliance program to address International Structuring and Profit Shifting (ISAPS). Tax and law professionals from external firms have been recruited into the ATO to help Read More