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Legal Analysis of Transnational Digital Service Taxation Issues in the Field of International Tax Law

  
Mar 17, 2025

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Figure 1.

The range of digital service taxes
The range of digital service taxes

Figure 2.

BEPS “double pillar” of international tax rules
BEPS “double pillar” of international tax rules

Figure 3.

The law of digital service tax
The law of digital service tax

Figure 4.

Tax challenges for digital service taxes
Tax challenges for digital service taxes

Figure 5.

Legal risk of digital service tax
Legal risk of digital service tax

Figure 6.

The revenue composition of amazon group in 2012-2022
The revenue composition of amazon group in 2012-2022

Figure 7.

France’s tax revenues account for a change in the proportion of GDP
France’s tax revenues account for a change in the proportion of GDP

The legislative status of digital service tax

Tax class Direct tax Indirect tax Total
legislated 42 104 146
Refuse to make public announcements/proposals 14 / 14
Draft legislation/public consultation 8 15 23
Wait for global solutions 11 4 15
Declare/intend to implement 9(Including China) 3 12

Relevant tax system elements

Country Progress of the bill Tax scope Income threshold
France Promulgate (extension until the end of 2020) The ratio of the “French digital presence” to the corresponding global digital service income is associated with the French tax service income section:

Provide a digital interface that enables users to connect with others and interact.

The advertising agent based on the number of users.

Global revenues of more than 750 million euros are worth more than 25 million euros in taxable income related to French user activity.
England Promulgate (April 1, 2020) From the UK, which belongs to the income of three kinds of words:

Social media platform.

Search engine.

Online market.

Global revenues are more than 500 million pounds, and it comes from Britain’s revenue of more than 25 million pounds.
Austria Promulgate (January 1, 2020) Digital service providers provide Austria with the revenue of advertising services. The turnover of taxpayers’ groups has exceeded the turnover of 750 million euros and digital advertising services more than 25 million euros.

National digital service tax registration

Region Country Opening time Collection range Tax rate
Digital service range Global turnover Domestic turnover
Europe France 2019.01 Digital business advertising and cross-border data flow and other digital transactions 750 million euros 25 million euros 3%
Italy 2020.01 Directional advertising and digital interface service 750 million euros 5.5 million euros 3%
Austria 2020.01 Online advertising 750 million euros 25 million euros 5%
Turkey 2020.03 Targeted advertising, social media and digital interface services 750 million euros 20 million Turkish lira 7.5%
England 2020.04 Social media, search engines and online marketing services 500 million sterling 25 million pounds euro 2%
Spain 2020.12 Online advertising, online intermediary services, sales users, etc. 750 million euros 3 million euros 3%
Czech 2021.06 Digital service 750 million euros 100 million kronor 5%
Aisa India 2020.04 E-commerce transactions 20 million rupees 20 million rupees 2%
Singapore 2020.01 Digital services related transactions Million new yuan 100,000 new yuan 7%
Malaysia 2020.01 Including audio and streaming media services 120,000 dollars 120,000 dollars 6%
Thailand 2021.09 Electronic service transaction 1.8 million baht 1.8 million baht 7%

The registration of the digital service tax

Region Country Opening time Collection range Tax rate
America Canada 2021.07 Global income is more than $759 million and domestic income of more than $30 million. 3%
Brazil 2020.01 Global income is more than $600 million, and revenue in Brazil is divided into three levels, with a different level of 3% and 5% tax. 1%,3%,5%
Mexico 2020.05 Global income is more than $5 billion and domestic income is more than $30 million 16%
Chile 2020.06 Global income is more than $5 billion and domestic income is more than $30 million 19%
Paraguay 2021.01 Global income is more than $5 billion and domestic income is more than $30 million 10%
Costa Rica 2020.10 Global income is more than $5 billion and domestic income is more than $30 million 13%
Africa Kenya 2021.01 Annual income of more than $5 million 1.5%
Tunis 2020.01 Annual income of more than $0.5 million 3%
Zimbabwe 2019.01 Annual assessment of more than $500,000 5%
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