Necesitamos nuevas reglas en la fiscalidad internacional

Abstract

This article analyzes the origin and the change in the rules of international taxation that are on the table as a consequence of the new economic and social reality in which we are living. Concepts such as residence, source and the arm’s length principle are being called into question because they do not solve the tax collection problems of the States. New ones are emerging, such as minimum taxation, which have nothing to do with physical presence, the basis of all traditional international taxation. In short, the old concepts do not solve the problems of everyday life, such as the maintenance of hospitals, schools or infrastructures.