Propuestas impositivas sobre la actividad económica digital

Maria Gabriela Lagos Rodríguez


The current economic environment is characterized by the relevance of technology in business models and also in the distribution channels of goods and services. These changes have not been harmless to tax systems. Traditional tax principles and figures are not capable of responding to current challenges, nor can changes be introduced at the pace that technological developments impose. In this context, the object of analysis in this work is the Proposals that the European Commission is putting forward in March 2018 as a response to the challenge of the digital economy. Proposals for Directives COM(2018) 147 and 148 final constitute a formal attempt to regulate the thorny problem of digital taxation, specifically to tackle the loss of resources that the current tax regulatory framework provides to large technology companies. The objective is to present and assess these proposals and to present a reflection on the nature of the tax on certain digital services and its possible application as opposed to the concept of significant digital presence.


taxation; digital economy; digital services tax; corporate taxation; significant digital presence


J.M. CALDERÓN, El Paquete Europeo (2018) en materia de Fiscalidad de la Economía Digital, en Carta tributaria. Revista de opinión, Nº39, 2018.


• Proposal for a Council Directive COM(2018) 147 final, Rules relating to the corporate taxation of a significant digital presence,

• Proposal for a Council Directive COM(2018) 148 final, On the common system of a digital services tax on revenues resulting from the provision of certain digital services,

• Communication from the Commission to the European Parliament and the Council, Time to establish a modern, fair and efficient taxation standard for the digital economy,

• European Data Market SMART, 2013/0063, 2017,

• Communication from the Commission to the European Parliament and the Council, A Fair and Efficient Corporate Tax System in the European Union: 5 Key Areas for Action,

HUAWEY & OXFORD ECONOMICS, Digital Spillover. Measuring the true impact of the Digital Economy 2017,


• Tax Challenges Arising from Digitalisation – Interim Report 2018: Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project, 2018, OECD Publishing, Paris,

• OECD Digital Economy Outlook 2017, OECD Publishing, Paris.

• Addressing the Tax Challenges of the Digital Economy, Action 1- 2015, Final Report, 2015.

• Action Plan on Base Erosion and Profit Shifting, OECD Publishing.


• Report of 22 February 2018 on the proposal for a Council directive on a Common Corporate Tax Base,

Report of 26 February 2018 on the proposal for a Council directive on a Common Consolidated Corporate Tax Base,

DOI: 10.6092/issn.2036-3583/10488


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