DIGITAL ECONOMY AND THE “TWO PILLAR APPROACH”: SOME REFLECTIONS ABOUT THE INHERENT CHANGES IN TAX PRINCIPLES AND IN TAX SOVEREIGNITY

In order to allow other countries, instead of the country of residence, to have a larger share in the profits of MNEs involved in the digital business, OECD and G20 are developing some new taxation principle which will entail the departure from the principle of residence which has been, so far, the basis of the international tax system. As much as the purpose is clear, we are not sure that the final outcome of such a project has been fully considered. This article aims at highlighting the potential impact of the new system both in terms of a waiver of each State to its sovereignty and in terms of the potential acquisition of the status of members of the international community by MNEs.

DIGITAL ECONOMY AND THE “TWO PILLAR APPROACH”: SOME REFLECTIONS ABOUT THE INHERENT CHANGES IN TAX PRINCIPLES AND IN TAX SOVEREIGNITY Continua