What Is the Road Ahead for Unilateral Digital Tax Measures?

In the past couple of years, countries across the globe have implemented several unilateral measures for digital economy taxation to tackle the tax challenges arising from taxation of the digital economy. On the global front, the Organisation for Economic Co-operation and Development (OECD) hosted negotiations with countries that are part of the Inclusive Framework on Base Erosion and Profit Shifting for more than half a decade and came up with a Two-Pillar Solution. The United Nations proposed a new article 12B, which aims to allow market jurisdictions to withhold tax on payments made for digital services. However, many open questions still need to be resolved, probably the most relevant of all – is there a certainty that multinationals covered in Pillar One or Pillar Two would not be doubly taxed on the same digital income? Considering this background, the paper starts with the discussion on the current state of affairs, then it moves on to the debate surrounding the taxation of the digital economy. It also discusses the various unilateral digital tax measures currently in existence across the globe and the macro and micro impact of these measures on the economy and businesses. It concludes with a discussion on what lies ahead for the countries adopting the OECD-proposed Two-Pillar Solution and the fate of the unilateral digital tax measures.