Facing International Tax Challenges arising from Digitalisation

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Type and Duration

FFF-Förderprojekt, July 2018 until November 2020


Chair for Tax Management and the Laws of Liechtenstein and International Taxation

Main Research

Wealth Management

Field of Research

Tax Reform


Increasing digitalization and the associated variety of business models made possible by technology and the evaluation of data volumes pose great challenges to the current income and consumption tax systems. Traditional taxation concepts that focus on "conventional business models" are increasingly reaching their limits and appear unsuitable for taxing not only the income of the so-called "digital giants" companies such as the "FAANG" (Facebook, Amazon, Apple, Netflix, and Google). More generally, these concepts are also not appropriate for other companies operating and particulary rendering services online. In the recent past, individual states but also supranational organizations such as the OECD and EU have therefore addressed this problem and discussed different approaches to the future effective taxation of profits of digitalised companies with several individual jurisdictions implementing unilateral variations of the proposals discussed.
In the course of this research project, a systematic and detailed analysis of unilateral tax measures and proposals for International Tax Standards discussed at the level of the OECD, G7, G20, and EU on how to address the tax challenges arising from digitalisation was conducted and potential implications for the Principality of Liechtenstein were identified. The analysis made apparent that the so-called "taxes on digital services", create significant management and interpretation problems. Results are unrelieved double taxation, which makes them a serious threat to the legal stability of the International Tax System as they were found to violate the Double Taxation Conventions, WTO law, and even European Union law. Such taxes were thus found to harm a tax jurisdictions' capabilities of attracting innovation and investments.
The spread of unilateral measures was parallelled by several proposales entered at the level of the G20/OECD Inclusive Framework on BEPS as well as at the level of the EU. Especially the proposals discussed in the G20/OECD Inclusive Framework are significantly more far-reaching than simply taxing "digital giants" but rather concern the reallocation of taxing rights on corporate profits with a significant shift towards destination-based taxation. The research project's results indicate the importance of a tax jurisdiction's commitment to implementing the currently discussed International and European Tax Standards to avoid the threat of double taxation, double non-taxation, and of being regarded as a future tax haven for digitalised businesses.

Project results:


Taxes, Tax Competition, Double Tax Agreement, Digitalization