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Publications
“Direct taxation in the context of the digital economy: virtual permanent organization, withholding tax and the Diverted Profit Tax”, in Rivista Trimestrale di Diritto Tributario, No. 4/2015, pages 895-922

The traditional institutions of international taxation show signs of subsidence in the face of digital enterprises coming to the fore, used to conduct their activities abroad without recourse to “physical” structures. In order to ensure, also in this new context, a fair distribution of taxing power between States, various solutions are hypotesized: the “virtual” permanent organization, a withholding tax on digital transactions and the Diverted Profit Tax.

All. Pedaccini – Direct taxation

Annex