Planning-ul fiscal ante-2021 al giganților publicitari. Sustragerea veniturilor din publicitate de la impozitare. Rolul domiciliului fiscal. Perspective pentru viitor
2021 ex-ante fiscal planning of online advertising giants. Tax avoidance for online advertising revenues. The role of tax residency. Prospects for the future

Summary/Abstract: Online advertising market is dominated by the advertising giants known as Google and Facebook. They are assigned the largest percentage of the global online advertising revenues. In the same time, online advertising constitutes their main and significant source of revenue. Advertising services, as a part of the digital economy, have a series of characteristics that are borrowed from the internet’s ones, and are based upon IP rights known as intangible actives. In the natural attempt to maximize the profits of the companies, Google and Facebook exploit the special characteristics of their services and IP rights, for tax purposes, in order to substantially reduce the tax base, creating a scheme in which tax residency plays a key role. Nevertheless, a mechanism that has been working for over a decade begins to be caught up by international tax professionals, and different obstacles are posed for breaking the tax schemes of the advertising giants, especially starting with 2021.

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