This study compares cross-border consumption taxation of digital supplies in business-to-consumer transactions from an international coordination perspective. Hence, the various classifications of digital supplies and the provisions for deciding the place of taxation are compared and examined to identify cases of double taxation and unintentional nontaxation or potential risks thereof. In addition, possible remedies for double taxation and unintentional non-taxation are discussed.

The findings in this study are evaluated on the basis of rationality, which refers to the consumption taxation upholding the principles that are part of the OECD models and the Ottawa Taxation Framework Conditions. The analysis is based on an evaluation model derived from the principles that are part of the Framework Conditions. These principles are: neutrality, efficiency, certainty and simplicity, effectiveness and fairness, and flexibility.

• Chapter One: Introduction
• Chapter Two: Legal Sources and Methods of Interpretation
• Chapter Three: Forming an Evaluation Model
• Chapter Four: Imposition of VAT and GST
• Chapter Five: Classification of Digital Supplies
• Chapter Six: Deciding the Place of Supply
• Chapter Seven: Double Taxation and Unintentional Non-taxation
• Chapter Eight: Final Conclusions

Pernilla Rendahl, LL.D., is currently working as an assistant professor in law at Jönköping International Business School (JIBS) in Sweden and participates in research projects carried out by the Media Management and Transformation Centre, JIBS. Her research and teaching focus is on value added taxation in an international context and EU law. Ms Rendahl received the European Academic Tax Thesis Award in 2009.

The mission of the International Bureau of Fiscal Documentation is: “[T]o maintain a knowledge centre providing information about and explanations of international taxation and promoting the study of taxation in general” (Art. 2 of the articles of association). True to this mission, and aware that access to doctoral theses is often limited, IBFD has taken the initiative to make available to a wider public a series of books based on doctoral research, meeting the highest academic standards.

Only contributions that enhance the international academic tax debate are accepted. In order to ensure high quality, every thesis published in this series has been reviewed by academic members of the Board of Trustees, senior IBFD research staff or prominent tax academics worldwide. The series aims to cover all aspects of comparative and international taxation, not only in respect of income tax, but also in respect of VAT and of inheritance, estate and gift taxes.

• Vol. 1 - The Concept of Income: A Multi-Disciplinary Analysis

      by Kevin Holmes

• Vol. 2 - Taxing Portfolio Income in Global Financial Markets

      by Doron Herman

• Vol. 3 - Free Movement of Persons and Income Tax Law

      by Servaas van Thiel

• Vol. 4 - Advance Tax Rulings and Principles of Law

      by Carlo Romano

• Vol. 5 - Arbitration under Tax Treaties

      by Mario Züger

• Vol. 6 - E-Commerce and Source-Based Income Taxation

      by Dale Pinto

• Vol. 7 - Interpretation of Tax Treaties under International Law

      by Frank Engelen

• Vol. 8 - Taxation of Investment Funds in the European Union

      by Tomi Viitala

• Vol. 9 - Taxation of Cross-Border Partnerships

      by Jesper Barenfeld

• Vol. 10 - Taxation of International Performing Artistes

      by Dick Molenaar

• Vol. 11 - Dispute Resolution under Tax Treaties

      by Zvi Daniel Altman

• Vol. 12 - Income from International Private Employment

      by Frank Pötgens

• Vol. 13 - Taxation of Investment Derivatives

      by Antti Laukkanen

• Vol. 14 - International Tax Planning and Prevention of Abuse

      by Luc De Broe

• Vol. 15 - EC Law Aspects of Hybrid Entities

      by Gijs Fibbe

• Vol. 16 - EU VAT System and the Internal Market

      by Rita de la Feria

• Vol. 17 - Formulary Apportionment for the Internal Market

      by Stefan Mayer

• Vol. 18 - Cross-Border Consumption Taxation of Digital Supplies
  by Pernilla Rendahl
• Vol. 19 - EC Law and the Sovereignty of the Member States in Direct Taxation

      by Dr Mathieu Isenbaert