Taxation and Value Creation

This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework.

Why this book?

The suggestion to “align international taxation with value creation” first emerged in the context of the OECD BEPS Project aimed at tackling aggressive tax planning strategies resulting in base erosion and profit shifting. The concept of “value creation” was then further relied on in the broader discussion that followed about the impact of digitalization on the global economy generally and the fair allocation of taxes between countries in this new environment. Although the idea – or the guiding principle – that profits should be taxed where economic activities occur and where value is expected to be created initially received a relatively large support, it rapidly became clear (at least to academics) that there would be no obvious answer to the question “where is value being created?” in a manner that would be relevant for (international) tax purposes, inter alia in view of the different models of value creation within corporate entities.

Based on 9 thematic reports (offering an interdisciplinary discussion of the concept of value creation mostly from an international perspective) and on 23 national reports (focusing on the meaning of value creation in domestic tax law), this book seeks to contribute to the discussion on whether the concept of value creation is viable, both theoretically and in practice, as a criterion for the allocation of taxing rights under a modernized international tax framework.

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This book is part of the EATLP International Tax Series

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Contributor(s)

Hrvoje Arbutina, Gabriel Bez Batti, Radim Boháč, Irene J.J. Burgers, Divesh Chawla, Richard Collier, Katja Dyppel Weber, Eva Escribano, Emrah Ferhatoğlu, Louise Fjord Kjærsgaard, Clemens Fuest, Stefanie Geringer, Danylo Getmantsev, Henrik Guldhammer Nielsen, Werner Haslehner, Sabine Kirchmayr, Dániel Máté Kovács, Marie Lamensch, Amy Lawton, Timo Lemm, Na Li, Emmanuel Llinares, Enguerrand Marique, Ralph Meghames, Jérôme Monsenego, Aitor Navarro, Rachel O’Connor, Shu-Yi Oei, Karl Pauwels, Katerina Perrou, Cees Peters, Michal Radvan, Ronald Russo, Patrick Schmid, Wolfgang Schön, Luís Eduardo Schoueri, Doğan Şenyüz, István Simon, Claus Staringer, Alain Steichen, Dario Stevanato, Raoul Stocker, Zsolt Szatmári, Timo Torkkel, Matthias Valta, Nicolas Vergnet, Petr Vodák, Bjorn Westberg, Güneş Yılmaz, Nataša Žunić Kovačević.

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