CORIT member Louise Fjord Kjærsgaard has published an article i World Tax Journal under the title “Allocation of the Taxing Right to Payments for Cloud Computing-as-a-Service”
In the article Louise analyses the options available to user jurisdictions for taxing the value generated by cloud computing service providers under current international tax rules. The focus is on mixed contracts, the distinction between business income and royalties and whether the provision of such services constitute a permanent establishment of the cloud computing service providers. Against this background, value creation and the fundamental principles of legal certainty, neutrality and the ability to pay tax are discussed.
The article is published in: World Tax Journal vol. 11 (2019) no. 3.