e From Thought….. ……To Finish 1.Tax Enforcement in Cyberspace 2.Expanded Opportunities for Tax Administrations The Challenge To Tax Administrations
e From Thought….. ……To Finish 1.Overview of VAT 2.Concept of Place of Supply Under VAT 3.Distinguishing Between Goods and Services 4.Distinctions Between Types Of Services The Challenge To Consumption Taxes
e From Thought….. ……To Finish Current International Tax Consensus Tax Treaties Principles of Tax Treaties Relevant to the Internet Implications of the Internet for the Permanent Establishment Concept Implications of the Internet for the Permanent Establishment Concept Implications for the Definition of Royalties The Challenge To Transfer Pricing The Challenges To Existing International Taxation Arrangements Embedded in Tax Treaties
e From Thought….. ……To Finish Issues Relating to the OECD Model Tax Treaty on Income and Capital What is the interaction of the Internet and the permanent establishment? Can a server or server space constitute a permanent establishment concept? Are there alternatives to the permanent establishment concept? Even if a permanent establishment is established, what income should be attributed to the PE?
e From Thought….. ……To Finish Issues Relating to the OECD Model Tax Treaty on Income and Capital (contd) How should income from transfers of technology over the Internet be characterised? Does it constitute business profits or royalties? Is there a need to amend the definition of royalties in the model treaty? Is there an erosion of source taxation?
e From Thought….. ……To Finish Issues Relating To Tax Avoidance and Evasion