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Sharing the rides but are we sharing the profits?


Ride-sharing services like Uber are posing major challenges to traditional taxation models. This is because business profits generated by Uber and similar companies are perceived to be “geographically divorced” from the provision of ride-sharing services themselves. To that extent, host countries that physically support the income-generating activities might lose out on the tax revenue because the “digital company” could be based in another country.

This article considers the OECD’s BEPS project against companies like Uber to determine how and where profits are made, and how the concepts of source and residence are applied to characterise income for tax purposes in a consistent way. This article also seeks to establish: (1) the taxation models in Australia, France and the United States that are applied to capture taxable income; (2) how income tax is captured at a personal level earned from employment; and (3) the enforceability of regulations in different local governments.

Author profiles

Tipei M Gambiza
Gambiza is a Masters Student at Curtin Law School.
Current at 1 June 2016 - Current at 14 July 2016
Prof Dale Pinto CTA-Life
Photo of author, Dale PINTO is currently Acting Dean of the Curtin Law School and is a Professor of Taxation Law and Head of the Taxation Department of the Curtin Law School at Curtin University. He is Vice-President of the Divisional Council of CPA Australia (WA Division) and is also a Fellow of CPA Australia, a Fellow of the Australian Academy of Law and is a Chartered Tax Adviser and Life Member of the Tax Institute. Dale is the author/co-author of numerous books, refereed articles and national and international conference papers, and is on the editorial board of a number of peer-reviewed journals as well as being the Editor-in-Chief of several refereed journals. Dale is the Chair of the Tax Institute's National Education Quality Assurance Board and is a member of TEQSA's Expert Panel in Accounting and Taxation. Dale served as an inaugural member of the National Tax Practitioners Board and is a current member of the Board of Taxation's Advisory Panel and the ATO's Tax Technical Panel (Superannuation), as well as the Tax Institute's Technical Committees (Superannuation, Not-for-Profit Organisations and Large Business and International). - Current at 05 February 2016
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