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Source taxation of cross-border intellectual supplies - concepts, history and evolution into the digital age.

Publication date: 01 Jan 07 | Source: BULLETIN FOR INTERNATIONAL TAXATION

Issue: Vol. 61 no. 1 2007

Pages: pp.2-16

This article examines the theory, history and operation of the question of "source of income" from the perspective of the taxation of intellectual property rights and of supplies of substantial intellectual content (intellectual supplies) under tax treaties and its implications and possible evolution in the e-commerce context and the digital age. Specifically, the article discusses the theory of source taxation of intellectual property; intellectual supplies and tax treaties - the distinction between royalties and business profits; intellectual supplies in the digital age - operation of existing rules; and towards a coherent framework for the taxation of intellectual supplies in tax treaties.

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Author profile

Dr Niv Tadmore CTA
Photo of author, Niv TADMORE Dr Tadmore is a Tax Partner at Clayton Utz. His key focus areas of practice are dispute resolution, international tax and transfer pricing. He has particular expertise in the energy & resources, high-tech, digital and manufacturing sectors. He represents The Tax Institute on the ATO’s Dispute Resolution Working Group, and is a member of the ATO’s Large Business Advisory Group and the Treasury BEPS Advisory Group. He was recently appointed to the global Executive Committee of the International Fiscal Association. - Current at 19 May 2017
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