Digital Taxation

4 ECTS / 24h / English

In a World that is fast entering the Digital Age, so inter-dependent of cross-border transactions and trade, international taxation principles face new and pressing challenges.

We have always learned that a Person carrying on business in more than one Country would only be taxed in the State of Residence unless such business was being carried on through a Permanent Establishment located in the other Country. The digitalization of the economy has allowed such Person to engage in very substantial activities in other Countries without ever needing to set up a Permanent Establishment in such other Countries, meaning that no taxes are paid in the State of the Source and all taxes are paid in the State of Residence – with the added factor that, when dealing with digital goods or services, the State of Residence can pretty much be any Country in the World, i.e., a no-tax or low-tax Country.

Our Seminar will deal with the impacts of digitalization in taxation and how international tax principles are to be adapted to this new reality. However, in order to understand what is about to come, one needs to understand what is. Therefore, our Seminar will first introduce you to the current concepts of international tax – such as the concepts of Person,

Residence, Permanent Establishment or Transfer Pricing – thereby allowing you to better understand how these concepts may change to accommodate a better distribution of the taxing powers between the State of Residence and the State of the Source.

Once such concepts are understood, you will then be able to see how they can best be adapted to a new Digital Age – if at all. We will deal with the OECD BEPS Project on Action 1 and with the work of the European Union on the taxation of digital services.

Hopefully, by the end of the Seminar, you will be able to have your own ideas on how Technology and Taxation can better be harmonized. Terms such as CRS (common reporting standard), E-Filings, E-Invoicing, Data Gathering (SAFT-T), Profit Split Method in Transfer Pricing, EU State Aid Cases, Digital Permanents Establishments and others will hopefully no longer be totally remote words.

And, for certain, you will have fun discussing these topics. After all, as a Person likely to earn income in more than one Country, taxation and double-taxation issues are likely to hit you hard at some point in the future.


Miguel Teixeira de Abreu is a law graduate from the University of Lisbon (1982/1987), with an LL.M. from the London School of Economics and Political Sciences…