Taxation of E-Commerce Transactions
:
State taxation. If on the other than the transactions were to be treated as one of
licensing, irrespective of the fact that there might be no permanent establishment
in the buyer's State, the amount paid by the buyer would, (according to most
double taxation avoidance agreements and most domestic tax laws), be
considered not as a sale consideration, but after a licence fee constituting a
royalty and this would therefore be subject to Host State taxation on the basis of
the Source Rule, the payer of the consideration being a resident of the Host
State.
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