OECD, France, Israel, Italy, Spain, UK, India, US and other countries which have enacted legislation: - Action BEPs Report - OECD Interim Report (March 2018) • Proposal of EU commission re Fair Taxation in digital economy: directive on digital PE profit allocation rules and a temporary 3% tax on digital services. Including online placement of advertising, sales of collected user data, digital platforms that facilitate transactions between users, 750 million Euro threshold and total annual revenue of $50 million Euros • Disappearing geographic boundaries • Is concept of permanent establishment irrelevant? Italian anti-avoidance, no physical presence required if significant and continuous presence • Wayfair Supreme Court - effect on digital economy • New financing structures in digital era - role of blockchain • Value creation for transfer pricing purposes in financial investment structures • Global mobility • How are insurance and finance sectors dealing with digital economy taking into account regulatory environment? • VAT and withholding tax issues for crowdfunding • Israel – Significant economic presence • India – Non-treaty countries threshold local and revenue and number of users. Online advertising and digital advertising - 6% on income over $1,500 US if NR does not have PE in India • UK – 20% WHT on payments made by a foreign company without a UK PE • Italy – 3% tax on value • Hungary - Advertisement tax, - B2B tax 5% / 5.3% / 7.5% - Exemption 320,000 Euros of turnover • UK and Australia – Diverted profit tax • Sale of advertising on a website • Procurement of goods on a website • Web tax on services provided through electronic means (eg Italy 3% gross payments due for services exclusive of VAT) • Accessing Netflix, Uber – tax? • Fintech