How Should Indonesia Implement Direct Tax on Digital Economy? – A Comparative Study between the Equalization Tax in India, and the Digital Service Tax in the United Kingdom and France

The digital economy has become part of our daily life and it brings many positive impacts to societies. On the other side, it raises challenges for taxation. Source countries, where the digital business earns income from, find difficulties to implement a provision in their domestic law or treaty to tax the income from the digital transaction. The OECD expects a consensus base solution to address this problem by the end of 2020. However, some countries, such as India, France and the United Kingdom, decided to implement a unilateral measure as an interim solution while waiting for the global consensus. The policy, the design and the implementation of the measure in each country are quite different. This paper aims to analyse the features of the unilateral measure implemented in the three countries. The study aims to figure out whether Indonesia should implement such unilateral measure, and how the policy, the regulation and the implementation should be.