The digitalization of the economy combined with sophisticated tax planning has enabled some multinationals to avoid paying almost any income tax in most market jurisdictions from which they earn substantial profits. Faced with financial and political pressures to act, market states have sought to expand their tax bases so that these multinationals, especially those providing internet advertising and digital intermediation services, pay their ‘fair’ share of tax. The failure to reach an agreed outcome among Organisation for Economic Co-operation and Development and Group of Twenty members has led to an increasing number of states to take unilateral measures. In doing so, states need to navigate their obligations under double taxation agreements and trade agreements. An examination of typical double taxation agreements, the General Agreement on Trade in Services, and recent preferential trade agreements shows that states have limited options to expand their tax bases in compliance with their international obligations. Here, the imposition of an appropriately designed digital services tax has political and legal advantages. The growing volume of cross-border digital services and data flows suggests that greater engagement between the international tax and trade regimes is likely in the future, including in the negotiations of disciplines on electronic commerce.
Unmanned Aircraft System (UAS) has been primarily used in the military domain, and their use has increased tremendously in the last decade. UAS provide several distinct operational capabilities and cost advantages compared to manned aircrafts in most situations. It has long been postulated that use of Unmanned Aircraft Systems (UAS) in the civil domain will enable overall improvement in effectiveness of performance in many civil applications currently performed by manned aircrafts and it will provide potential long term cost savings for the UAS operators. UAS would also give rise to whole host of new applications, which have not yet been envisaged. However the civil UAS industry has not yet started due to the restricted access of UAS in segregated areas of the national airspace and inability to routinely access national airspace alongside manned aircrafts. This paper proposes that the integration of UAS in nonsegregated airspace is a complex system-of-systems problem with a level of difficulty well beyond the technical challenges involved in the development, implementation and validation of the system.The routine operation of UAS in national airspace is as much of a political and emotional issue because the aviation regulatory authorities are swayed as much by current political environment and public perception towards the issue. Beyond public concerns, the system design problem is inherently complex. The size and lower costs are two major benefits of UAS. However to design a UAS which has high safety standards and follows same level of equivalence and transparency as manned aircrafts without compromising on two major advantages of UAS, is a big challenge.
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