Understanding the problematic issues of the global reform of international taxation of digital companies

The author's interest in the topic of the article is caused by the fact that in the context of a new geopolitical reality, the process of transformation of the international tax order and, within its framework, the rules for taxation of profits of foreign digital companies is accelerating. In the article,  the author analyzes and comprehends the problematic issues of the reform of international taxation carried out by the Organization for Economic Cooperation and Development (OECD) at the global level. The author gives an assessment of the International Approach to taxation of profits of digital companies developed by the OECD and implemented by it. The article also analyzes the author of a new approach proposed by the OECD to the distribution of global profits received by digital companies from the supply of digital products in the market of foreign jurisdictions for users of these products. In addition, the author identifies the legal grounds and expediency of introducing a tax on digital services by some states.

In order to achieve the goal of sustainable economic development of states, an effective solution to  the problem of international taxation of profits of digital companies is becoming increasingly important. The global community of states and their tax administrations face a strategic task: to achieve a situation in which the international tax system will reflect all trends in the development of the digital economy. To achieve this goal, it is necessary to achieve coherence between the actions of States at the regional and global levels.

 Due to the significant increase in the volume of activities of foreign digital companies, the digital business has increased the need to develop and implement a unified international approach to taxation of income of digital companies and primarily Multinational companies (TNCs) received from the supply or digital services (products) to the markets of foreign jurisdictions.  In the context of the active development of the digital economy, scientists and practitioners faced a question that requires a clear answer – on what grounds and to what extent the procedure for taxation of corporate income within the digital economy differs from the procedure for taxation of corporate income in the traditional economy.

 With the expansion of the scale of digital business projects, the number of the largest digital companies (the so-called giants) is growing, new digital facilities are being allocated, the number and geography of users' consumption of digital products is increasing, and the number of user contracts they conclude using digital company data is growing. 

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