The idea to tax the digital economy shifts slowly towards new taxation rights and new profit allocation rules that may affect more than just tech companies.
On 9 October 2019, the OECD published a proposal to tax Multinational Enterprises (“MNE”) wherever they have significant B2C relations (the “Unified Approach Proposal”). The Unified Approach Proposal is the result of ongoing discussion at the OECD level and aims notably to answer the question of how to allocate taxing rights on income generated from cross-border activities in the digital age among different jurisdictions.
Despite the first initiatives aimed at taxing big digital companies such as GAFA (Google, Amazon, Facebook and Apple), the scope of the Unified Approach Proposal goes even further. It now aims at amending the current international taxation principles more generally with a view to adapt them to the digitalisation of the economy and to introduce a new taxing right for market jurisdictions.