New European and international taxation perspectives. The case of the italian´s web taxation. Towards the taxation of the data economy and global minimum tax
Authors: Giambrone Filippo Luigi 
Published: April 2024

The age of the internet and digital commerce has brought about complexities in taxation, particularly concerning multinational digital corporations. International discussions have sought ways to ensure fair taxation of these entities, but consensus has been challenging to reach. The paper aims to understand Italy's digital taxation measures, its alignment (or conflict) with EU directives, and the global efforts towards taxing digital multinational enterprises. In its document analysis, the research meticulously scrutinized Italy's taxation laws, giving particular emphasis to Article 17-bis and the Budget Law of 2018. Through comparative analysis, the research delved deep into EU directives, notably the Directive Proposal COM (2018) and the Directive 2006/112/EC, with the intent of discerning the harmony or disparities with the prevailing Italian statutes. Using historical analysis, the research charted the trajectory of international dialogues on digital taxation, commencing with the G7 in Bari in 2017, progressing to the G20 in Buenos Aires in 2018, and encapsulating subsequent summits. Turning to policy analysis, the research methodically probed into the nuances of the "Next Generation EU" recovery plan alongside the OECD's avant-garde two-pillar model. Finally, within its quantitative analysis, the research embarked on an exploration of the conceivable repercussions of the proposed thresholds for both revenue and profit rates. In its appraisal of Italy's Web Tax, the research reveals that the nation's digital tax harmonizes with VAT in spirit. However, it predominantly emphasizes B2B digital transactions, thus deviating from the recurrent mechanism that defines conventional VAT. As for the vision of the European Union, the research underscores the EU's ambition, channelled through Directive Proposal COM (2018), to institute a cohesive VAT transaction system for cross-border B2B merchandise. Notably, Italy's digital taxation approach doesn't seamlessly dovetail with this vision. With respect to the global consensus, the research elucidates that subsequent to the ravages of the COVID-19 pandemic, international discourse has exhibited a marked tilt toward the inception of a global minimum tax. Such a tax is envisioned to guarantee the equitable taxation of digital multinationals, uninfluenced by their geographical operational outposts. Delving into challenges, the research posits that the actualization of universal taxation standards is not without its hurdles. Nuanced challenges like revenue thresholds imply that a mere handful of corporations may come under its ambit. The intricate task of adapting to ever-shifting digital landscapes and the formidable challenge of reigning in the dark web further complicate the equation. Gazing into the future trajectory, the research intimates that contemporary accords hint at the prospective dissolution of individualized digital service taxes by the horizon of 2023. This is seen as a stepping stone toward a global minimum tax paradigm. Anticipations include the evolution of domestic directives, the fortification of bilateral agreements, and the emergence of a cohesive multilateral instrument. Yet, the stance of certain EU member nations remains enshrouded in uncertainty. In conclusion, while the digital age has brought about unmatched growth and opportunities, it has also surfaced complexities in its taxation. Italy's efforts, in sync with global moves, underscore the growing need for a comprehensive and fair digital taxation framework. However, the path to uniformity and consensus remains intricate and will require coordinated international collaboration.