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Aqib Aslam and Ms. Alpa Shah

fraught. It would seem that if user data is indeed being exploited at a scale large and wide enough for it to be both recognized as an economic input to production and protected on behalf of the user, it should be recognized for all businesses. With these issues in mind, this paper attempts to understand more comprehensively the role that “user-generated value” can and/or should play in determining the structure of the future corporate tax system. To begin with, both businesses and government would need to agree and acknowledge that there is such a thing as user

Aqib Aslam and Ms. Alpa Shah
The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.