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The authors highlight that the actual principles of international taxation are insufficient to effectively tax the digital economy. The main objective is to make compatible the need for territorial connection within the jurisdiction and the business structures of companies that own digital platforms. Regarding territorial connection, the authors explain that the provinces and City of Buenos Aires only have the authority to tax when economic activity is carried out in their territory. However, the structure of the digital economy falls outside this tributary power, as digital platforms and their administration are located and operated outside specific provincial territories. They conclude that attributing income to corporate entities that, based on their actual functions, lack the material possibility to generate that income would indirectly violate the territoriality principle that underpins local taxation.

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