The New “Google Tax”: The “Start of the End” for Tax Residence as a Connecting Factor for Tax Jurisdiction?

Luca Cerioni

Research output: Contribution to journalArticlepeer-review

Abstract

This article assesses whether the new Diverted Profit Tax (DPT) introduced by the UK (and commonly known as "Google Tax") may be regarded or not as an implementation of the academic proposal for a "Destination Based Corporation Tax" (DBCT), and it tests the DPT against double tax treaties, against the OECD's BEPS Action Plan and against the EU's fundamental freedoms.
Original languageEnglish
JournalEuropean Taxation
Volume55
Issue number5
Early online date22 Apr 2015
Publication statusPublished - 2015

Keywords

  • Google tax
  • destination based corporation tax
  • tax residence

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