Innovation and Taxation: A Fundamental Approach to Nexus in BEPS Action 5 and 1

Research output: Chapter in Book/Report/Conference proceedingChapterAcademic


In this work I discuss (i) reductions limiting the net return (deductions, withholdings on gross income and allocation of income to the source state) and, (ii) issues related to the treaty characterization of software, digital products and automated digital services. In that turbulent scenario, my research shows that the supply side of innovation needs urgent attention from an academic and a policy perspective.
While this research presents a fundamental and different approach to innovation
and taxation, it invites to reconsider the impact of BEPS Actions 1 and 5 through
the lens of innovation policy, with a particular reference to the European Union
and in some cases to less economically developed countries.
Original languageEnglish
Title of host publicationTax Nexus and Jurisdiction in International and EU Law
EditorsEdoardo Traversa
Place of PublicationAmsterdam
Number of pages55
ISBN (Electronic)9789087227975
ISBN (Print)9789087227968
Publication statusPublished - Nov 2022
EventWebconference | Nexus and Jurisdiction in EU and International Tax Law: Open Roundtable “Nexus and developing countries : the impact of OECD Pillar I and II” - Online, Louvain, Belgium
Duration: 17 Sept 202018 Sept 2020

Publication series

SeriesGREIT Conference Series


ConferenceWebconference | Nexus and Jurisdiction in EU and International Tax Law
Abbreviated titleGREIT 2020
Internet address


  • Digital economy
  • nexus
  • innovation
  • International taxation

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