European Union

Spokespersons for Parliament and for the political groups will hold a briefing on the 6 - 9 October plenary session, on Friday at 11.00 in Parliament’s Anna Politkovskaya press room.

Source : © European Union, 2025 - EP

Written by Pieter Baert.

Taxing the digital economy raises complex challenges, as traditional tax rules struggle to keep pace with new business models and technologies. The Subcommittee on Tax Matters (FISC) will organise an Inter-parliamentary Committee Meeting (ICM) on digital taxation on 18 October 2025, bringing together counterparts from national parliaments across the EU.

Scale without mass: The challenge of taxing digital value creation

Designing effective tax policies for the digital economy is particularly challenging, given its rapid evolution and the rise of diverse activities such as streaming, e-commerce, online gaming, and cloud computing. Each of these areas may carry distinct tax implications that traditional tax frameworks may struggle to address. At the same time, the wider economy is becoming increasingly digitalised, blurring the boundaries between digital and non-digital sectors.

One of the most fundamental challenges stems from the difficulty (national and international) tax systems have in capturing the phenomenon often described as ‘scale without mass’. Since the 1920s, international corporate taxation has been built around the principle of physical presence: once a company is deemed to have a sufficient level of physical presence in a country, that country gains the right to tax the profits attributable to that company. This model fitted well into the 20th-century ‘bricks and mortar’ economy, where business growth in a country was strongly tied to greater physical presence (such as offices, employees, and machinery). However, the digital economy disrupted this logic, allowing companies to reach vast foreign markets with minimal physical infrastructure.

Another distinct feature is how digital companies leverage user-generated value to varying extents, with user data shaping sales and marketing strategies. Users may contribute passively (e.g. by browsing) or actively (e.g. by uploading content), which is crucial for algorithms and network effects-driven models, such as social media or online marketplaces. By providing data and content in return, users are seen as playing an unprecedented role in companies’ value-creation process.

Together, these shifts raise the question of whether current tax rules align with the realities of where value is created in the digital economy, fuelling debate on how to reform international taxation.

The rise of digital services taxes

To address these challenges, several countries have introduced a digital services tax (DST). Although there is no universally agreed definition, DSTs are generally understood as taxes on turnover – rather than profit – with revenues allocated to the jurisdiction in which customers or users are located, rather than where the company is established. These measures generally target large multinational enterprises and primarily apply to revenues derived from activities closely linked to user participation, such as the sale/monetisation of user data, targeted online advertising, and providing digital intermediation services (i.e. online platforms that connect users, such as social media), though the precise scope and definitions may differ between countries. Several countries have already implemented DSTs with revenues steadily increasing over time, showcasing the continuous growth of the digital economy. The United States (US) administration has strongly criticised DSTs and their use in Austria, France, Italy, Spain, Turkey and the United Kingdom (UK).

Table 1 – Revenue of DSTs (€ million), 2019-2023

Revenue (€ million)20192020202120222023Spain  166295323France277375474621668Italy 233303394434

Data source: Data on Taxation Trends – European Commission (latest data updated in March 2025).

Three EU countries apply a 3 % DST on revenue from online advertising, user data sales and providing digital platforms, with a €750 million global revenue threshold and varying domestic thresholds: €3 million (Spain), €25 million (France), and €5.5 million (Italy; lowered to €0 in 2025) – see Table 1.

Although categories such as social media, online search engines, and online marketplaces may appear conceptually straightforward – and are often associated with well-known global firms – the task of formulating clear and robust legal definitions for these activities in a fast-evolving digital landscape is considerably more complex, with legislation often leaving some leeway for the ‘facts and circumstances’ of each service. Countries may issue technical guidance on in-scope services, and the calculation of taxable revenues, etc. (see, for example, France, Italy, Spain and the UK).

For instance, defining what counts as a ‘social media service’ is not straightforward. Authorities may distinguish whether a service’s main purpose is to promote interaction between users (or with user-generated content), or whether such interaction is incidental. But terms like ‘interaction’ may be left undefined, and it can be difficult to tell apart services that truly promote interaction and those that simply enable it in the background. For multinational enterprises, the challenge can be compounded by subtle differences in guidance and interpretation across countries with DSTs, creating uncertainty and disputes.

Similarly, identifying in-scope revenues can be difficult when companies have revenues from both in-scope and out-of-scope activities, requiring them to separate and attribute revenues accordingly. Moreover, companies need to include those revenues that are related to a taxable digital service and that are related to a user in the jurisdiction introducing a DST. However, an online advert on a search engine or social media platform may normally be shown to multiple users. This means the revenues could be related to both users from a DST jurisdiction and a non-DST jurisdiction. In such cases, companies would need to apportion those revenues correctly.

‘Pillar One’ – A new approach to international taxation?

In October 2021, nearly 140 countries from around the world rallied behind a historic overhaul of international corporate tax rules to modernise taxation for the digital era through a ‘two-pillar’ solution. Pillar One puts in place a new tax regime that would allocate taxing rights over a portion of the profits to countries in which companies’ products are consumed (known as ‘market jurisdictions’), regardless of whether the company has a physical presence in those market jurisdictions. Pillar One exclusively targets the world’s largest and most profitable (digital and non-digital) companies.

Pillar One has yet to be enforced, pending the stalled signing of a Multilateral Convention. The US administration has repeatedly criticised Pillar One, arguing that it disproportionately targets US firms.

During the September 2025 European Parliament plenary session, in response to questions from Members of the European Parliament on the state of play of Pillar One and the prospects for a European DST, the European Commission acknowledged that Pillar One discussions were ‘on hold’ but could resume later this year. To give the OECD-led process space and time to deliver, the Commission stated that it does not intend to table a new proposal for a DST at this stage.

Read this ‘at a glance’ note on ‘Taxing the digital economy‘ in the Think Tank pages of the European Parliament.

Newsletter - 6-9 October 2025 - Strasbourg plenary session

Source : © European Union, 2025 - EP

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