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The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions

The digital economy is rapidly evolving and changing the way businesses operate. This is as a result of the increased use and reliance of technologies in business processes. As more companies adopt technology in their operations and as technology is continually developing, it becomes cheaper to impl...

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Main Author: Harnekar, Zafar
Other Authors: Roeleveld, Jennifer
Format: Thesis
Language:English
Published: Department of Finance and Tax 2016
Subjects:
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access_status_str Open Access
author Harnekar, Zafar
author2 Roeleveld, Jennifer
author_browse Harnekar, Zafar
Roeleveld, Jennifer
author_facet Roeleveld, Jennifer
Harnekar, Zafar
author_sort Harnekar, Zafar
collection Thesis
description The digital economy is rapidly evolving and changing the way businesses operate. This is as a result of the increased use and reliance of technologies in business processes. As more companies adopt technology in their operations and as technology is continually developing, it becomes cheaper to implement technology in business processes over time. Traditional tax principles, domestic and international are reliant on some level of physical activity being performed in a country before the taxing right is granted. In the past, businesses required a level of physical presence in each country they operated in, in order to generate a significant level of economic activity. However, through the use of technology, businesses are now able to centralise their core business functions by operating on a global or regional level, and thereby foregoing the need to establish subsidiaries or branches in the countries they operate in. As a result of this, businesses are able to separate the location of the activities that generate economic value from the physical location of the customer. This creates tax challenges as businesses are able to manipulate their operations such that their 'core business activities' are performed in low tax jurisdictions. Base erosion and profit shifting (BEPS) has been on the agenda for a number of years as countries have become increasingly concerned about profits being shifted to other jurisdictions. At the request of the G20 leaders in 2013, the Organisation for Economic Co-operation and Development (OECD) prepared a 15 point action plan in order to address such concerns. The final version of the report was released in September 2015.Action Plan 1 of the report deals specifically with the tax challenges raised by the digital economy. The report states that the recommendations in the report in its entirety will address BEPS risks, but specifically that Action Plan 7 will serve to mitigate any risks introduced by the digital economy.
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institution University of Cape Town (South Africa)
language eng
last_indexed 2026-06-10T12:34:17.944Z
license_str Not specified — see source repository
provenance_str_mv Harvested via OAI-PMH from UCTD — University of Cape Town Open Access Repository
publishDate 2016
publishDateRange 2016
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publisher Department of Finance and Tax
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spelling oai:open.uct.ac.za:11427/20377 The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions Harnekar, Zafar Roeleveld, Jennifer Taxation The digital economy is rapidly evolving and changing the way businesses operate. This is as a result of the increased use and reliance of technologies in business processes. As more companies adopt technology in their operations and as technology is continually developing, it becomes cheaper to implement technology in business processes over time. Traditional tax principles, domestic and international are reliant on some level of physical activity being performed in a country before the taxing right is granted. In the past, businesses required a level of physical presence in each country they operated in, in order to generate a significant level of economic activity. However, through the use of technology, businesses are now able to centralise their core business functions by operating on a global or regional level, and thereby foregoing the need to establish subsidiaries or branches in the countries they operate in. As a result of this, businesses are able to separate the location of the activities that generate economic value from the physical location of the customer. This creates tax challenges as businesses are able to manipulate their operations such that their 'core business activities' are performed in low tax jurisdictions. Base erosion and profit shifting (BEPS) has been on the agenda for a number of years as countries have become increasingly concerned about profits being shifted to other jurisdictions. At the request of the G20 leaders in 2013, the Organisation for Economic Co-operation and Development (OECD) prepared a 15 point action plan in order to address such concerns. The final version of the report was released in September 2015.Action Plan 1 of the report deals specifically with the tax challenges raised by the digital economy. The report states that the recommendations in the report in its entirety will address BEPS risks, but specifically that Action Plan 7 will serve to mitigate any risks introduced by the digital economy. 2016-07-15T11:21:51Z 2016-07-15T11:21:51Z 2016 Master Thesis Masters MCom http://hdl.handle.net/11427/20377 eng application/pdf Department of Finance and Tax Faculty of Commerce University of Cape Town
spellingShingle Taxation
Harnekar, Zafar
The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions
thesis_degree_str Master's
title The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions
title_full The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions
title_fullStr The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions
title_full_unstemmed The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions
title_short The source of income from the sale of goods electronically: an analysis of the division of the taxing rights in cross-border solutions
title_sort source of income from the sale of goods electronically an analysis of the division of the taxing rights in cross border solutions
topic Taxation
url http://hdl.handle.net/11427/20377
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