Our tax experts have advised a group of companies doing business in digital economy (i. e. video games, sales of virtual images, etc.). In order to avoid accusation of tax treaty shopping, the core question of this advice was related to the substance requirements of a holding company. Also, an advised related to taxation of a cross-border transfer of intellectual property. Since the taxation of global digital economy and combating aggressive tax planning is one of the hottest topics on the G20 agenda, our advice was based on the newest trends in the BEPS action plans.
A deep analysis of the OECD’s discussion draft on Digital Economy allowed our tax team to predict a future and provide top quality advice regarding substance requirements for the holding company and optimal taxation of cross-border transfer of the intellectual property.