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Digital economy; new paper a useful
contribution to reform debate
TAX advisers have welcomed the
Treasury's 'Position Paper' consulting on ways of modernising the
international Tax system to Tax the 'digital economy' more effectively.
Glyn Fullelove, Vice-President of the Chartered Institute of Taxation,
commented:- "Governments continue to struggle to reconcile the perception
from their citizens that 'internet giants' have a significant 'footprint' in
economies where they have a lot of sales but relatively little other presence,
with an international corporate Tax system that Taxes value creation, and
attributes little if anything of that to sales activity."
The CIOT welcomes the Government's statement in the Position Paper that the UK
remains committed to the principle of Taxation where value is created. It is
realistic and sensible to try to sustain the internationally negotiated and
agreed basis for allocating Taxing rights between countries. But the Institute
recognises that further work is needed internationally on modernising this
framework, and the Position Paper represents a useful contribution to this
process.
The Chancellor announced in his Budget statement that the UK will in any event
proceed with one unilateral measure, a withholding Tax on intellectual property
('IP') royalty element of payments for digital services provided to the UK from
abroad, where the IP is held in a low Tax jurisdiction. The CIOT notes that the
revenue forecasts from this measure contain a cautionary message about the
effectiveness of unilateral measures without broader international agreement. It
is expected to raise ₤285m in its first year, declining to ₤130m, in 2022 to 2023, its
4th year of operation, in part because the affected multinationals can be
expected to adjust their structure and behaviours to mitigate the effect of the
Tax
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