ORIGINAL RESEARCH article
Front. Polit. Sci.
Sec. Politics of Technology
Volume 7 - 2025 | doi: 10.3389/fpos.2025.1561283
New Rationales for Taxing the Digital Economy: Lessons from the Pillar One Consultations
Provisionally accepted
- 1George Mason University, Fairfax, United States
- 2Schar School of Policy and Government, George Mason University, Arlington, Virginia, United States
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This paper documents and categorizes nontraditional arguments for the taxation of multinational digital firms. While centered on stakeholder responses to the OECD's Pillar One consultation process, the study aims to capture a broader conceptual landscape of how taxation can respond to the unique challenges of digitalization. These arguments, while not always reflected in final policy outcomes, may gain salience as AI technologies increasingly decouple value creation from physical presence. Drawing on 296 stakeholder submissions, the paper identifies a range of justifications for new value creation standards. These include shifting taxing rights away from residence-based physical presence rules, internalizing the societal costs of misinformation and surveillance, treating user data extraction akin to natural resource severance, and using taxation as a regulatory tool to check digital platform power. In doing so, the paper provides a taxonomy of emerging ideas that may inform future international tax debates.
Keywords: International tax, International tax avoidance, Artificail intelligence (AI), Tax justice, pillar 1
Received: 15 Jan 2025; Accepted: 11 Aug 2025.
Copyright: © 2025 Listokin. This is an open-access article distributed under the terms of the Creative Commons Attribution License (CC BY). The use, distribution or reproduction in other forums is permitted, provided the original author(s) or licensor are credited and that the original publication in this journal is cited, in accordance with accepted academic practice. No use, distribution or reproduction is permitted which does not comply with these terms.
* Correspondence: Siona Listokin, George Mason University, Fairfax, United States
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