"Current income (profit) taxation of robots" [2019] ELECD 1235; in Oberson, Xavier (ed), "Taxing Robots" (Edward Elgar Publishing, 2019) 44

Book Title: Taxing Robots

Editor(s): Oberson, Xavier

Publisher: Edward Elgar Publishing

Section: Chapter 6

Section Title: Current income (profit) taxation of robots

Number of pages: 17

Abstract/Description:

Chapter 6 describes how the use of robots currently is subject to income or profit tax at the level of the enterprises owning them. Indeed, as part of the assets and investments of any enterprises, profits or income emerging form the use of robots are subject to profit tax. The chapter shows how activities of enterprises using robots, both from a domestic and international standpoint, are apprehended by the tax system. In particular, the use of automation abroad may be treated as a permanent establishment from a double taxation treaty perspective. The peculiarities of the use of smart robots, instead of humans, may require a reassessment of current recommendations on the allocation of profits between a PE and the head-office, notably on the concept of “key persons”.