14 Accepted

The Chartered Institute of Taxation describes the Digital Services Tax as a ‘blunt instrument’.43 There...

Conclusion
The Chartered Institute of Taxation describes the Digital Services Tax as a ‘blunt instrument’.43 There are aspects of the tax’s design that are tolerable in the short-term but would need to be addressed if its life was to be extended appreciably: • The Digital Services Tax is a tax on revenues. If the activities are profitable, the business may also pay corporation tax or corporate income tax on those activities in the country where those profits are taxed.44 HMRC does have provision for businesses to be exempted from payment if they can demonstrate that the activities in question are not profitable (called the alternative basis of charge).45 • The Expedia Group, one of the payers of the tax, pointed out to us in written evidence that for high-volume low-margin businesses such as themselves and other travel firms, a 2% tax on revenues effectively wipes out any profit.46
Government Response Summary
The government agrees that HMRC has already completed an evaluation of DST implementation, applying lessons learned to other tax policy changes, and reiterates that DST is an interim solution whose impact is under constant review.
Government Response
Accepted
HM Government Accepted
The government agrees with the Committee’s recommendation. Recommendation implemented HMRC carries out an evaluation on the implementation of all measures that require new or updated systems and processes. This was completed for DST following the implementation of the new return system with lessons learned being considered and applied across HMRC’s portfolio of tax policy changes. This includes looking for opportunities to re-use existing solutions and applying proportionate IT changes to drive cost efficiency. The government has always said that the optimal solution would be a multilateral solution on reallocation of taxing rights. However, pending a multilateral solution, the government decided to implement a pragmatic interim solution. In line with guidance agreed within the OECD, the DST is focused on the businesses for which the policy concern is considered most relevant and for which administrative burdens are considered most manageable. While the DST is an interim solution, the government keeps tax policy, including the impact of the DST, under constant review. The government has since implemented other taxes learning lessons from the design and implementation of DST. Other measures that have used thresholds to target the tax in line with both policy and administrative considerations are the Residential Property Developer Tax and the Electricity Generator Levy.
Addressee Bodies
HM Treasury
Timeline
Recommendation age 3.3 yrs
Report published 05 Apr 2023