ScholarWorks@숙명여자대학교

초록

With the Advent of the Fourth Industrial Revolution, digital economy has made a new type of MNEs which has a business foundation of digital platform. Multi-national tech companies, so called GAFA(Google-Apple-Facebook-Amazon), operate their business based on this global platform, which is ended in international tax issues of Permanent Establishment(PE) and virtual PE. This has brought bout the conflects of jurisdiction to tax between home and host countries. The concept of virtual PE has continued its discussion among professional groups in OECD and EU. In OECD BEPS Action Plan, BEPS Action 1 tried to figure out the types of digital business rooted on the issued of international taxation. More recently, EU commission added talks on international tax issued on GAFA company, in the form of EU Commission Report. In the study, I tried to introduce the discussion raised by OECD and EU Commission by summarizing and comaparing the international tax issues among professional groups. Then, I tried to draw down the possiblity of tax risk aftermath of implementing BEPS Action Plan and EU Report in the near future. Finally, I reached conclusion that the importance of international taxation in the digital economy might be focused on virtual PE issues and re-definition of PE adopting ‘nexus’ concept.

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