E-Commerce and Source-Based Income Taxation
Author: Dr Dale Pinto - Doctoral Series: Vol. 6
Summary

The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment. However, the thesis also argues that the way in which the source of income is defined needs to be reconceptualized because the application of source-based taxation under traditional principles may be rendered problematic in light of certain characteristics of electronic commerce that are significant from a tax perspective.

Main contents
  • The Theoretical Foundations and Rationale for Source-Based Taxation.
  • The Definition of Source and Identification of Characteristics of Electronic Commerce Which Suggest a Need to Reconceptualise the Way Source is Defined for both Active Business Profits and Passive Income.
  • Reconceptualising Source for Active and Passive Income: The Base Erosion Approach, The Virtual Permanent Establishment Approach, The Refundable Withholding Approach
About the author
Dr Dale Pinto is an Associate Professor and Head of the Taxation Department at Curtin University in Perth, Western Australia. He has published extensively in both national and international journals and has presented papers at several national and international conferences. He was the inaugural winner of the Australian Commissioner of Taxation‘s Award for Research in Taxation, a prestigious award for research scholarship in taxation.
About IBFD Academic Council
IBFD Doctoral Series is an initiative of IBFD Academic Council, a body established in 2000 to promote the discussion of international tax law at a high academic level and to stimulate the academic activities of IBFD. The Academic Council evaluates projects according to the sole criterion of their academic quality. Its members are appointed from among prominent academics and senior IBFD research staff members.
Every thesis published in this series has been reviewed by the Academic Council to ensure that it is of a high quality.
Other books in IBFD Academic Council's Doctoral Series:

      by Dr Zvi Daniel Altman

      by Luc De Broe

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