[PDF] Is Big Data That Simple An Analysis Of The Transfer Pricing Aspects Of Value Creation Of Data In The Digitalized Economy eBook

Author : Victor S. Calijuri
Publisher :
Page : 0 pages
File Size : 14,16 MB
Release : 2023
Category :
ISBN :

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Data steers the digitalized economy. The transformation of data into valuable information is somewhat comparable with traditional research and development activities and has become one of the most valuable intangibles for many companies. The knowledge discovery method in databases, known as “data mining”, needs to be studied conceptually to demonstrate that the arm's length principle cannot effectively allocate profits to jurisdictions. Nevertheless, much effort has been put into OECD's Pillar One, but is it indeed ready to deal with the big data economy? To answer this question, the author briefly introduces the evolution of transfer pricing and presents that the dichotomy between the arm's length principle comparability completeness and the formulaic apportionment simplicity were merged to create a more robust system to tackle the challenges of the digitalization and lack of physical presence. In a data-driven economy, it is essential to understand the steps involved in the value creation of data. The purpose of the present study is to meticulously delineate the value chain of big data, including collection, processing and analysis and monetization of the data. In conclusion, the author suggests a framework that effectively allocates profits in accordance with the value creation of data.

Author : Raffaele Petruzzi
Publisher : Kluwer Law International B.V.
Page : 275 pages
File Size : 19,66 MB
Release : 2022-01-13
Category : Law
ISBN : 9403501774

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Information Law Series #48 About this book: Imposing Data Sharing among Private Actors is a vital book shedding light on the nature of certain economic and societal balancing exercises required for any compulsory business-to-business (B2B) data-sharing initiatives because data sharing involves both benefits and potential costs. While the economic value originating from data sharing seems evident, identifying the legal framework to be applied to it is a challenge. This is due to the multiple claims and rights aimed at controlling, accessing or benefiting from data processing. What’s in this book: Whether these initiatives pursue economic, societal or empowerment objectives, their potential benefits must be balanced with the following three considerations that are extensively investigated in the book: the economic interests of the data holder; personal data protection considerations; and long-term and collective costs in terms of individual autonomy. The analysis elucidates how these aspects have been factored into existing compulsory B2B data-sharing initiatives so far (particularly in Europe), and on how they may be used as a source of inspiration in future initiatives. Insightful suggestions on the implementation of these balancing exercises conclude the volume. How this will help you: Based on law and literature in competition, personal data protection and intellectual property, the book greatly highlights the necessary balances underlying compulsory B2B data sharing and raises awareness about the crucial need to take the risks involved into consideration. It will be highly appreciated by policymakers, academics and private actors interested in issues linked to competition law in the digital environment, regulation of platforms, data governance or the interaction between competition law and personal data protection law.

Author : Annika Streicher
Publisher : Linde Verlag GmbH
Page : 533 pages
File Size : 11,72 MB
Release : 2023-10-13
Category : Law
ISBN : 3709413001

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The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.

Author : José María Cavanillas
Publisher : Springer
Page : 312 pages
File Size : 47,67 MB
Release : 2016-04-04
Category : Computers
ISBN : 3319215698

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In this book readers will find technological discussions on the existing and emerging technologies across the different stages of the big data value chain. They will learn about legal aspects of big data, the social impact, and about education needs and requirements. And they will discover the business perspective and how big data technology can be exploited to deliver value within different sectors of the economy. The book is structured in four parts: Part I “The Big Data Opportunity” explores the value potential of big data with a particular focus on the European context. It also describes the legal, business and social dimensions that need to be addressed, and briefly introduces the European Commission’s BIG project. Part II “The Big Data Value Chain” details the complete big data lifecycle from a technical point of view, ranging from data acquisition, analysis, curation and storage, to data usage and exploitation. Next, Part III “Usage and Exploitation of Big Data” illustrates the value creation possibilities of big data applications in various sectors, including industry, healthcare, finance, energy, media and public services. Finally, Part IV “A Roadmap for Big Data Research” identifies and prioritizes the cross-sectorial requirements for big data research, and outlines the most urgent and challenging technological, economic, political and societal issues for big data in Europe. This compendium summarizes more than two years of work performed by a leading group of major European research centers and industries in the context of the BIG project. It brings together research findings, forecasts and estimates related to this challenging technological context that is becoming the major axis of the new digitally transformed business environment.

Author : Edward Curry
Publisher : Springer Nature
Page : 399 pages
File Size : 17,26 MB
Release : 2021-08-01
Category : Computers
ISBN : 3030681769

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This open access book presents the foundations of the Big Data research and innovation ecosystem and the associated enablers that facilitate delivering value from data for business and society. It provides insights into the key elements for research and innovation, technical architectures, business models, skills, and best practices to support the creation of data-driven solutions and organizations. The book is a compilation of selected high-quality chapters covering best practices, technologies, experiences, and practical recommendations on research and innovation for big data. The contributions are grouped into four parts: · Part I: Ecosystem Elements of Big Data Value focuses on establishing the big data value ecosystem using a holistic approach to make it attractive and valuable to all stakeholders. · Part II: Research and Innovation Elements of Big Data Value details the key technical and capability challenges to be addressed for delivering big data value. · Part III: Business, Policy, and Societal Elements of Big Data Value investigates the need to make more efficient use of big data and understanding that data is an asset that has significant potential for the economy and society. · Part IV: Emerging Elements of Big Data Value explores the critical elements to maximizing the future potential of big data value. Overall, readers are provided with insights which can support them in creating data-driven solutions, organizations, and productive data ecosystems. The material represents the results of a collective effort undertaken by the European data community as part of the Big Data Value Public-Private Partnership (PPP) between the European Commission and the Big Data Value Association (BDVA) to boost data-driven digital transformation.

Author : N. Srinivasan
Publisher :
Page : pages
File Size : 22,63 MB
Release : 2019
Category :
ISBN :

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The OECD's BEPS project mandated that transfer pricing outcomes under the arm's-length standard should be aligned with value creation. In the digital economy, new business models are challenging transfer pricing practitioners on how best to apply the value creation approach. In a two-part series the authors illustrate the complexities and challenges posed by digital business models. The first article explored the digital economy and the OECD's work on BEPS Action Item 1 (taxing in the digital economy). This second article is a case study of the Internet of Things (IoT), which builds and uses a stylized transfer pricing analysis to explore the transfer pricing challenges posed by an IoT ecosystem.

Author : Xavier Oberson
Publisher : Springer Nature
Page : 227 pages
File Size : 23,27 MB
Release : 2023-12-02
Category : Law
ISBN : 3031433726

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This book has the merit of being the first book analysing different aspects of data taxation from a wide perspective encompassing not only tax law but also other significant issues related to data, such as data protection and economic inefficiencies. The main aim is to provide data-specific solutions to data-driven problems. In the midst of a number of critical issues and a great deal of uncertainty currently reigning in the field, the authors attempt to put forward easy-to-implement and efficient proposals on the basis of an interdisciplinary analysis. The core idea of this book consists of segregating the utilisation of data into four different yet interdependent steps and constructing the tax law analysis on top of these four corner stones. Step one, occurring in the generation and collection phases of the data’s life cycle, comprises ‘the digital barter’ and other collection of data. Step two, taking place during the processing and analytics phases of the data’s life cycle, consists of microwork. Step three, situated in the storage, processing, analytics and use phases of the data’s life cycle, encompasses aggregation and internal use of data. Step four, materialising during the distribution and use phases of the data’s life cycle, covers sale of data, transfer of data and granting the right to use a database. The main issues occurring in each of the four steps are analysed separately, and yet interdependently, with an emphasis on international tax law. The book also comprises a VAT analysis; suggestion of a new type of tax, namely «data collection tax»; and a brief opinion on a potential future «robo-data tax». The subjects explored in this book are of interest for researchers, lawyers as well as tax administrations. Albeit being an academic publication, the developments made in this contribution are also relevant for the general public. After all, data, the youngest intangible, constitute the raw material of the fourth industrial revolution; and their use and taxation affect each and every citizen!

Author : Raffaele Petruzzi
Publisher : Linde Verlag GmbH
Page : 472 pages
File Size : 32,37 MB
Release : 2019-09-02
Category : Law
ISBN : 370941038X

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Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax treaties and analyzing terms of the OECD Transfer Pricing Guidelines alongside their factual context is the aim of this book. Here, law students address Transfer Pricing and Value Creation in sectors as varied as commodities trade, automotive, consumer products, food and beverages, pharmaceutical and life sciences, telecommunications, and the key topic of value creation in a digitalized economy. Our LL.M. students were required to address issues not explored in legal research and to discuss factual topics relevant for Transfer Pricing. All students focused on topics that are new to the international tax debate that keep evolving and on factual matters that often escape legal research.

Author : Ravikant Gupta
Publisher : Bloomsbury Publishing
Page : 532 pages
File Size : 28,90 MB
Release : 2017-06-15
Category : Business & Economics
ISBN : 938614171X

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About the book The growing importance of the intangible assets in the global economy coupled with expanding international intra-firm trade, has meant that transfer pricing issues concerning intangibles have assumed critical importance for both the Multi National Enterprises as well as Tax authorities. The identification, accounting & valuation of intangibles is a challenging and evolving field. This volume details the various such issues and concerns from both industry and revenue perspective. Further, the contemporary issues of digital economy, tax planning, BEPS, GAAR have also been extensively dealt with. Key features · Explains in detail the meaning of various types of intangibles as defined in Income Tax Act. · Discusses the various possible methodologies for valuing the intangibles including the typical and residual methods · Accounts for all the relevant changes suggested by the OECD in the BEPS Action Point 8-10 report regarding intangibles · Valuation of Highly Uncertain as well Hard-to-Value Intangibles · Relevant Features of and taxation challenges posed by Digital economy · Various possible techniques of Tax Planning adopted by the Multi-national Enterprises · All the BEPS Action Point Reports along with recommendations as adopted globally as well as in India including Thin Capitalisation, PoEM, Equalisation Levy, amended DTAAs with Mauritius, Cyprus & Singapore {Updated upto Finance Bill, 2017 (India)} · Transfer Pricing Aspects of CCAs, Intra-group Services & Business Restructuring including issue of indirect transfers · Discussion on General Anti Avoidance Rules, to be implemented in India from 01/04/2017 · Famous and important global and Indian case laws with regard to intangibles · Detailed discussion on issue of AMP expenses & marketing intangibles

Author : Cristian Óliver Lucas-Mas
Publisher : World Bank Publications
Page : 217 pages
File Size : 39,86 MB
Release : 2021-03-10
Category : Business & Economics
ISBN : 1464816557

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Digital technology allows businesses to operate in a country without a physical presence, which poses challenges for traditional taxation. The digital debate focuses on direct taxation and the creation of new taxing rights arising from the tax claims of market jurisdictions on income obtained by foreign digital suppliers conducting business therein without any physical presence. Tax Theory Applied to the Digital Economy analyzes the tax-disruptive aspects of digital business models and reviews current tax initiatives in light of traditional tax theory principles. The analysis concludes that market countries’ tax claims are unsubstantiated and contravene the most basic foundations of tax theory, giving rise to a series of legal, economic, tax policy, and tax administration issues that policy makers cannot overlook. The authors propose establishing a digital data tax (DDT) that is a license-type consumption tax, rather than an income tax, on the international supply of Internet bandwidth to access digital markets. The DDT can be applied either globally or unilaterally, and could become a significant source of tax revenues for market jurisdictions. It is aligned with tax principles and it does not conflict with other tax initiatives: the DDT taxes foreign digital companies as consumers, while income tax proposals tax them as suppliers. The authors also propose creating a new global internet tax agency (GITA) under the auspices of the United Nations that would provide a neutral forum for political discussion and technical assistance in the area of digital taxation. The digital economy is a global phenomenon that requires a global solution: the creation of global taxing mechanisms and global institutions that provide technical assistance and support for successful global implementation. The book explains difficult technical concepts in plain language and contributes to the digital tax debate in a way that can be understood by anyone. Such understanding is essential to obtaining global support, achieving tax compliance, and fostering multilateral tax cooperation.