Taxation of the digital economy in the United Kingdom, Italy and Hungary

The "digital economy", a well-established notion in international tax law, is problematic for national legislatures and causes concern in the realm of international administrative assistance. At issue is the fundamental basis of the jurisdiction to tax: the genuine link between income generated by a digital business model and a specific territory, which is not easily identifiable under existing international tax concepts and far from digital economic reality. Multinational digital enterprises, however, are especially able to benefit from tax planning strategies that are even more favored by outdated international tax concepts. Negotiations and efforts to find international consensus on adaptations of existing tax concepts to intangible business models have been lengthy and so far unsuccessful. Consequently, recently some States have begun implementing unilateral measures to modernise digital economy taxation. This note presents the solutions of the United Kingdom, Italy and Hungary to adapt their income tax systems to the digital economy