Challenges And Responses To The Principles Of Value Creation In International Taxation In The Digital Economy

The wave of digital economy has swept the world.Over the past 15 years,the value added of China's digital economy has expanded from 1.66 trillion yuan to35.8 trillion yuan in 2019,accounting for 36.2% of GDP from 14.2%.With the rapid development of digital economy,it also brings arduous challenges to the governance of digital economy.The current international tax rules and regulations are unable to keep up with the changes in cross-border business practices in the digital economy,especially in areas where digital economy and intangible assets are active.Under the background of digital economy,the traditional international tax system based on physical existence is facing challenges.The phenomenon of transnational tax avoidance by enterprises of digital economy using intangible assets and global value chain arrangement is widespread.In 2015,OECD proposed the principle of "Taxing Where Value is Created" to deal with the tax avoidance practices of companies that artificially separate the place where economic activities take place from the profits generated by the companies.Face challenges under the digital economy of tax,the OECD in 2019 "the digital tax economic challenge work plan",including "pillar 1" three new profits method is presented based on the value creation principle and the introduction of "of the existence of significant economic" tax coupling degree,to solve the problem of global digital economy enterprise profit tax found a way out.First of all,based on previous studies and from the perspective of enterprise value chain,this paper innovatively proposes that the elements of value creation principle in international taxation under traditional economy are: value creation elements,value creation contribution and value creation place;In view of the digital economy under the enterprise value chain structure and the digital economy's influence on the enterprise value creation principle 3 elements,this paper discusses the digital economy value creation in the international tax under the principle of the four challenges facing,and it is concluded that under the digital economy value creation principle of malfunction,multinational enterprises using the value chain of global tax leads to the conclusion of value creation and tax belonging deviating.Secondly,Uber,a typical digital economy enterprise ride-sharing software enterprise,is selected as the research object to analyze its use of global value chain arrangement and intangible assets related transactions to build a tax avoidance structure of "the United States--double Holland--Bermuda",and successfully parachute-profits into the tax haven Bermuda's global tax structure.By combining the analysis of Uber's global value chain,elements of value creation,contribution of value creation and place of value creation,it reveals the phenomenon that Uber's adoption of global value chain arrangement leads to the deviation between corporate value creation and tax ownership,and confirms the challenge that digital economy brings to the principle of value creation.Finally,in order to improve the value creation principle,reduce the digital economy enterprises tax avoidance,build a fair competition environment,protect the interests of the market the tax,and reflects on the countries,this paper introduced digital economy to cope with the tax policy and the OECD,the latest achievements of the digital economy challenge,challenge to appeal 4 put forward the corresponding countermeasures are suggested.