An Analysis of Actions of the OECD Action Plan on BEPS in the Digital Economy

Inhaltsverzeichnis (Table of Contents)

• Introduction
• Problem Definition
• Aims and Non-Aims
• Methodology and Structure
• Definitions of Technical Terms
• Direct and Indirect Taxes
• Permanent Establishment
• Attributes and Growth of the Digital Economy
• Development and Impact on the Business Environment
• Different Business and Revenue Models in the Digital Economy
• E-Commerce
• Application Stores
• Cloud Computing
• Online Advertising
• Overview on the Principal Characteristics of the Digital Economy
• Concepts of the International Taxation System
• The Role of the OECD in International Taxation
• Principles of International Taxation
• Double Tax Treaties and Taxation of Cross-Border Transactions
• Challenges of Taxing the Digital Economy
• The Role of PEs in the Digital Economy
• BEPS in Terms of Direct Taxation
• BEPS Relating to Indirect Taxation
• Evaluation of Countermeasures
• Amendments to Transfer Pricing Rules
• Methods Against Artificial PE Avoidance
• Measures Against Artificially Positioning Income in Low-Tax Jurisdictions
• Actions for the Prevention of BEPS with Regard to Indirect Taxation
• Discussion
• Conclusion and Future Outlook

Zielsetzung und Themenschwerpunkte (Objectives and Key Themes)

This bachelor thesis analyzes the actions of the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) in the digital economy. The study aims to examine the challenges of taxing the digital economy and evaluate the effectiveness of countermeasures implemented by the OECD.

• The growth and characteristics of the digital economy
• The challenges of applying traditional tax principles to the digital economy
• The OECD's BEPS Action Plan and its focus on addressing tax avoidance in the digital economy
• The effectiveness of countermeasures such as amendments to transfer pricing rules and measures against artificial permanent establishment (PE) avoidance
• The implications of BEPS for both direct and indirect taxation

Zusammenfassung der Kapitel (Chapter Summaries)

The introduction sets the stage by defining the problem of taxing the digital economy, outlining the study's aims and methodology, and clarifying key terms like direct and indirect taxes, and permanent establishment (PE). Chapter 2 delves into the attributes and growth of the digital economy, exploring its impact on the business environment and examining different business and revenue models, such as e-commerce, application stores, cloud computing, and online advertising. Chapter 3 provides a framework for understanding the international taxation system, focusing on the role of the OECD, the principles of international taxation, and the significance of double tax treaties in cross-border transactions. Chapter 4 addresses the challenges of taxing the digital economy, specifically the role of PEs, the impact of BEPS on direct taxation, and the challenges related to indirect taxation. Chapter 5 evaluates the effectiveness of countermeasures implemented to address BEPS in the digital economy, including amendments to transfer pricing rules, measures against artificial PE avoidance, and strategies for preventing BEPS in the context of indirect taxation. Chapter 6 offers a discussion of the findings, while the conclusion summarizes the key insights and provides an outlook on future developments in the field of digital taxation.

Schlüsselwörter (Keywords)

The core concepts explored in this thesis include the digital economy, BEPS, OECD Action Plan, international taxation, transfer pricing, permanent establishment, direct taxation, indirect taxation, and tax avoidance.