Is cloud computing a challenge to the traditional concept of a permanent establishment? – Part 1

21 Mar 2014 / Tax

This article discusses cloud computing services and the OECD approach on taxing digital services using traditional international tax principles. It presents the main discussions on such approach by doctrine and also more recently by OECD, through its BEPS Report. This is the first part of the article that introduces the main characteristics of cloud services and their regulatory framework within the European Union, encompassing problems of location of service providers, resources and data. Also, it is presented an introduction to the traditional tax concepts applicable to permanent establishment, especially in relation to source taxation and its foundations. [Published at International Tax Report – Informa UK Ltd –  March 2014, p. 01-10].

Article – cloud computing