International Comparison of Taxation Models in the Formulation of Digital Tax Rules
DOI:
https://doi.org/10.66069/ojspub.26820703Keywords:
Digital tax, International tax rules, Taxation models, Digital services tax, Consumption tax, Cross-border taxation, Tax policy comparisonAbstract
The formulation of international digital tax rules represents a pivotal issue in global tax reform and international tax governance, with significant implications for the development of the global digital economy. This paper systematically examines the taxation models adopted by typical countries in implementing digital tax rules, categorizing them into two major approaches: the standalone digital services tax (DST) model and the expansion of existing turnover tax model. Through a comparative analysis of representative countries adopting the standalone DST model including France, Italy, Austria, the United Kingdom, Spain, and Canada, this study examines core tax elements including taxable objects, tax rates, thresholds, and collection mechanisms. The analysis reveals that while these countries share common features in targeting core digital economy sectors and employing dual threshold criteria, they exhibit notable differences in the scope of taxable objects, rate structures, and legal liability provisions. Furthermore, this paper examines countries that have incorporated digital services into their existing consumption tax systems, including South Korea, Japan, Australia, Malaysia, Indonesia, the Philippines, and Brazil. The comparison highlights differences in implementation timelines, tax rate structures, and collection emphases across these jurisdictions. The findings provide both theoretical references and practical insights for the refinement of international digital tax rules and the construction of adaptive tax systems.
References
Liao Y. Addressing the Challenges of the Digital Economy to the International Tax Legal Order [J]. International Taxation,2015(3):20-25 (in Chinese).
OECD. Tax Challenges Arising from Digitalisation – Report on Pillar One Blueprint [R]. OECD Publishing, 2020.
Lu Y. Digital Services Tax: Theory, Policy and Analysis [J]. Taxation Research,2019(6):72-77 (in Chinese).
Heering J, Crasnic L, Newman A. When digital taxes come due: national digital taxes and the negotiation of the OECD inclusive framework [J]. New Political Economy, 2025, 30(2): 178-193.
Qiu F. International Practice and Enlightenment of Digital Tax [J]. Southwest Finance,2020(3):13-24 (in Chinese).
Zhang M. User Value and the Logic of Digital Tax Legislation [J]. Chinese Journal of Law,2022,44(4):112-131 (in Chinese).
Hay J, Chen X. "Taxing Where Value is Created" and the OECD/G20 Base Erosion and Profit Shifting Project [J]. International Taxation,2018(6):31-37 (in Chinese).
Ma H, Cao M, Bai Y. The Logic of OECD's International Tax Reform Schemes for the Digital Economy and China's Response: An Analysis Framework Based on New Market Public Finance [J]. Contemporary Finance and Economics,2022(1):29-39 (in Chinese).
Vella J. Digital services taxes: principle as a double-edged sword [J]. National Tax Journal, 2019, 72(4): 821-838.
Zhao T.A Critique of the Hybridity of European Digital Tax Systems: Based on the European Court of Justice's Rulings on Digital Services Tax [J]. Journal of Comparative Law,2024(3):180-191 (in Chinese).
Sun Y. The Divergent Paths of Digital Tax Legislation and China's Response [J]. Law Science, 2024(8): 176-192 (in Chinese).
Mpofu Favourate Y.. Taxing the Digital Economy through Consumption Taxes (VAT) in African Countries: Possibilities, Constraints and Implications [J]. International Journal of Financial Studies, 2022, 10 (3): 65-65.
Zhang J, Li Z, Xiao M. Global Digital Economy Tax Rule Adjustment Trends and Reflections [J]. Taxation and Economy,2020(4):95-99 (in Chinese).
Chen L, Wang T, Luo Z. International Experience and Reference of VAT Systems for Cross-Border Digital Transactions [J]. International Taxation,2019(2):31-35 (in Chinese).
Li H. Reflections on International Tax Rules for Income Attribution under Digital Economy Business Models [J]. Taxation Research,2018(7):76-83 (in Chinese).