Several international organizations are in the process of cooperation to deal with the issues arising, related to taxing e-traded products and services. The first time Organization of Economic Cooperation and Development, World Trade Organizations and European Union were begun study related to taxation of e-commerce and e-trade that negotiated among nations and organizations was 1998 Ottawa Conference. This decision related with electronic commerce was appropriated all world nations. There has not been any project yet produced to tax the electronic commerce in Turkey. In this study, decisions based on the work completed by Organization of Economic Cooperation and Development, World Trade Organizations and European Union related to electronic commerce are evaluated with Turkish tax system.

HOW TO FIGHT BASE EROSION AND PROFIT SHIFTING AND E-TRADE ?

1.Address the tax challenges of the digital economy

 

2.Neutralise the effects of hybrid mismatch arrangements

3.Strengthen CFC* rules

4.Limit base erosion via interest deductions and other financial payments

5.Counter harmful tax practices more effectively, taking into account transparency and substance

6.Prevent treaty abuse

7.Prevent the artificial avoidance of PE** status

8.Assure that transfer pricing outcomes are in line with value

  •         Intangibles
  •         Risks and capital
  •         Other high-risk transactions

9.Establish methodologies to collect and analyse data on BEPS and the actions to address it

10.Require taxpayers to disclose their aggressive tax planning arrangements

11.Re-examine transfer pricing documentation

12.Make dispute resolution mechanisms more effective

13. Develop a multilateral instrument

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  • FC: Controlled Foreign Corporation

PE Status: Permanent Establishment