At the intersection of tax and digital transformation

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To keep abreast of the latest tax developments in the rapidly developing global digital economy check out At the intersection of international tax and digital transformation on a regular basis. Here, our tax and technology professionals, from member firms around the world, share their insight and technology perspective on topics of interest to executives faced with taxation issues resulting from disruptive innovation and technology-enabled digital transformation. 

EY is a regular contributor to CCH’s Global Tax Weekly and I am pleased to announce that our column, At the intersection of international tax and digital transformation, is now also available on with the publisher's, Wolters Kluwer, permission.

We look forward to sharing our insight and experience with you, and to receiving your comments and ideas for future topics to address. Please email your comments and suggestions to me.

Channing Flynn, EY

Channing Flynn
International Tax Partner and
Global Technology Industry Tax Leader
Ernst & Young LLP

At the intersection: Framing 2017 - US tax reform impact on the technology sector

April 2017: US tax reform impact on the technology sector – In this edition of our column, we provide an overview of recent US tax reform proposals and their domestic and international tax implications for companies operating within the technology sector. Each section details what tech companies in various subsectors should consider as new tax legislation looms on the horizon. The impact of the various recent proposals released on 26 April 2017 by the Trump Administration will influence this discussion as well, but those new developments are not highlighted within this version.

At the intersection: Framing 2017 - A new digital tax diciplineJanuary 2017: Framing 2017 - a new digital tax discipline – In this issue of our column we kick off with a look back at tax issues and developments that occurred in 2016 and a look ahead for what to expect in the coming year. Rapid change and sudden shifts in tax rules and administration will not abate in 2017. Nor will there be a slowdown in the pace of digital innovation.

Just-in-time taxationNovember 2016: Just-in-time taxation – Topics covered: Preview of 2016 US election and the tax landscape; Mexico initiates electronic audits; Italian tax authorities rule on virtual currency and the sharing economy; Ruling in Denmark: data center doesn’t always create a PE; Spanish Supreme Court confirms broad interpretation of PE; Australian transfer pricing guidance to impact profit attribution in global value chains; UK enacts anti-hybrid mismatch rules and expands royalty withholding regime; Swiss tax reform aims to maintain its competitiveness in a rapidly changing environment, with patent boxes, R&D deductions and lowered corporate rates; Israel proposes innovation box regime to attract IP investments; Taiwan Cabinet proposes to tax cross-border e-commerce; European Commission finds Ireland granted illegal State aid and orders a recovery; and US finalizes its active royalty exception on subpart F income.

June 2016: Cascading BEPS impactsJune 2016: Cascading BEPS impacts: new digital taxes, precedents and publicity – Topics covered: India introduces a digital equalization levy; Israel digitally expands the definition of PE; European Commission proposes public tax reporting; UK anti-avoidance campaign turns focus on royalties; Canada sets up transfer pricing paradox on R&D; Spanish Supreme Court issues ruling on net equity payments; Japan implements OECD transfer pricing rules; European Commission seeks to modernize VAT; and Sharing-economy taxation rising on the agenda.


EY - 2016: a year of living uncertainlyMarch 2016: Private equity meets public policy on new ground – Topics covered: Private equity (PE) firms face new tax challenges amid growing technology M&A; Australia presses anti-avoidance law; Digital currencies subject to diverse tax interpretations; Italy taxes print, digital publications alike; Turkey looks to document e-commerce activity; and Russia planning VAT on cross-border electronic services.

EY - 2016: a year of living uncertainlyJanuary 2016: A year of living uncertainly– In this issue of our column we take a look back at tax issues and developments that occurred in 2015 and a look ahead for what to expect in 2016.

EY - Digital economy tax spotlight sweeps across BEPS, state aid and patent boxesNovember 2015: Digital economy tax spotlight sweeps across BEPS, state aid and patent boxes– Topics covered: Base erosion and profit shifting project (BEPS Project) guidelines released, but digital economy work continues until 2020; state aid cases reflect on transfer pricing, advance tax rulings; nations look to evolve intellectual property (IP) tax regimes; e-commerce warehouses in the crosshairs; Latin America trending toward more online taxes; and data protection issue roils EU–US flows.

EY - OECD BEPS Project: New world order or open seasonSeptember 2015: OECD BEPS Project: New world order or open season?– Topics covered: Will Chicago’s streaming media tax set a precedent?; Gauging the rising tide of indirect digital taxes; German authorities eye tax changes on cross-border licenses and royalties; Saudi Arabia adds “virtual service PE” to the tax lexicon; US proposal would aid on-shoring of IP; Excerpts from an interview with OECD’s Raffaele Russo; and US Tax Court invalidates IRS ruling on cost-sharing of stock-based compensation.

EY - July 2015: OECD BEPS Project coming into the home stretchJuly 2015: OECD BEPS Project coming into the home stretch– Topics covered: Communicating in an era of tax transparency; Australia crafts digital taxation; Italy may consider taxing virtual presence; OECD BEPS Project due to wrap up.

EY - At the intersection of international tax and digital transformation May 2015: The new geography of taxation– Topics covered: OECD’s proposals to prevent the perceived artificial avoidance of permanent establishment (PE); the impact of value added tax/goods and services taxes (VAT/GST) on technology companies; the growing technology hubs in India; the emergence of digital-specific taxation in Greece, Israel, New Zealand and the US; Australia and UK positions regards perceived cross-border profit diversion.

EY - At the intersection of international tax and digital transformation April 2015: Unraveling tax issues in the value chain– Topics covered: Digital technologies/cross-border intragroup/
intercompany services; Israel’s tax authority update; The Obama administration update on proposed taxing companies that operate in the digital realm; update on US tax guidance that addresses potential tax rate disparities in sales of goods manufactured overseas; French government-affiliated think tank update; a look inside the Silicon Valley model taxing meals and entertainment – along with the full menu of tax rules that apply.