The Impacts of Digitalisation in the Attribution of Profits to Permanent Establishments

Abstract

The thesis is devoted to an analysis of the impact of digitalisation on international taxation and approaches to address the associated problems. The research examines the concepts of source and residence, permanent establishment and its inability to be effective mean for taxation of digital economy. Both coordinated proposal and unilateral measures for expansion of the concept of permanent establishment and implementation of digital service taxes were assess on consistency with the Ottawa Taxation Framework Condition. The research offered an optimal way for taxation of the digital economy, taking into account doctrinal proposals and the establishment of the Global Tax Authority, ensuring effective administration of the international tax system.