A collection of the brief insights throughout April 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update.
2 April 2019 - PwC's comments on UK's user participation proposal
All three Pillar 1 proposals stated their purpose to address the policy goal of taxing income where it is sourced (i.e. value where it is produced). The “user participation” proposal limits itself to certain business models (social media, search engines, online marketplaces), “ring-fencing” a sliver of the overall digitalising economy, while the “marketing intangibles” and “significant economic presence” proposal would have a wider application. In that context the following comments may be useful.
The above is an extract from our comments on the OECD's Public Consultation Document - for the full text of our response, see here.
