International Company Taxation in the Era of Information and Communication Technologies

Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.

As a result of the progress in information and communication technologies (ICT) economic activities have become less dependent on time and place. This is leading to manifold changes in economic structures. Consequently, the question is whether and to what extent the existing rules of international company taxation are still applicable in an appropriate way.

Anne Schäfer analyses the current issues of international company taxation with regard to the economic changes induced by the use of ICT and provides reform approaches for international company taxation which cover the whole system of international taxation. She presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.

Autorentext
Dr. Anne Schäfer promovierte bei Prof. Dr. Dr. h.c. mult. Otto H. Jacobs am Lehrstuhl für allgemeine Betriebswirtschaftslehre, Treuhandwesen und Betriebswirtschaftliche Steuerlehre II der Universität Mannheim. Sie ist in der Steuerabteilung einer internationalen Wirtschaftsprüfungsgesellschaft in Brüssel tätig.

Inhalt
Changes to Economic Structures Through ICT.- Fundamental Concepts of International Taxation.- International Tax Planning in the Era of ICT.- Normative Criteria for Optimal Taxation.- Application of International Tax Law to the Changed Organisational Structures.- Reforming International Taxation.- Summary.