المعالجة الضريبية للمنشأة الدائمة في ظل التحولات الرقمية

الملخص EN

The digital economy indicate that it is an economy based on the internet and global digital platforms, so the international market has become driven by networks and informational momentum, and value is created all over the world through complex instantaneous interactions, the digital economy poses many challenges, especially the difficulty of proving a digital transaction and the ease of data manipulation, the immaterial existence of parties and paper documents, and the creation of disputes between countries regarding determining which country has the sovereignty to impose and collect tax on these transactions, so countries and organizations rushed to confront these challenges, announcing their reform program as an attempt to keep pace with this digital challenges through introducing new mechanisms compatible with the digital reality.

accordingly, it has become clear that the current tax systems are deficient in dealing with the digital economy, as the principle on which these taxes are imposed has not yet been determined, and e-commerce is mobile in terms of its technical servers, which are easy to transfer.

to tax shelters, it is therefore impossible to implement the idea of a permanent digital institution as a tax basis, highlighting the role played by international tax cooperation and coordination to find real and fair solutions.