International Company Taxation in the Era of Information and Communication Technologies

Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.

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The increased use of information and communication technologies (ICT) is leading to noticeable changes within the organisational structure of the economy. Geographical distances within companies as well as between companies and their customers can be bridged more easily with the use of ICT. Thus, economic activities are less dependent on time and place. Taking into account the manifold changes in the economic structures, it has to be questioned whether and to what extent the current rules of international company taxation are still applicable in a reasonable way. With regard to this issue, a need for the development of suitable reform approaches covering the whole system of international taxation still existed. The doctoral thesis of Mrs. Schafer provides a major contribution to fulfill this need. Mrs. Schafer has worked out in a very comprehensive way the creation of new organizational structures as well as the resulting implications on tax law and the system of international taxation. Moreover, the existing literature on the subject at hand has been analyzed in a competent way. The special merit of the doctoral thesis of Mrs. Schafer consists in elaborating reform proposals for international company taxation which cover the different relevant issues of international taxation.