e-Commerce & Internet : Direct tax issues
RKG Consulting can assist you with advice and implementation in connection with the following corporate income tax issues relating to e-commerce and internet transactions.
- e-Tax: Permanent Establishment
Under the OECD model treaty, a permanent establishment or PE is defined as being a “fixed place of business through which the business of an enterprise is wholly or partly carried on”. Questions immediately arise as to: * Can a computer server or web site be regarded as a fixed place of business given the technological [...]
- Tax analysis of e-Commerce transactions
We have tabulated below some categories of typical e-commerce transactions and their tax implications. The list is not intended to be exhaustive. We have provided examples for a few categories by giving a brief outline of a typical transaction scenario and then discussing the direct tax implications. If you are interested in knowing the tax consequences of any of the [...]
- Tax characterisations of e-commerce transactions
The following tax treaty income characterisation issues were identified by the OECD working party dedicated to this matter: Business profits and payments for the use of, or the right to use, a copyright. Business profits and payments for know-how. Business profits and payments for the use of, or the right to use, industrial, commercial or scientific equipment. Provision of [...]