IPBA 2021

Digitalization Changes the World – How Does it Change the Tax World?

Organised by: Tax Law Committee

Session abstract:

Digitalization is putting pressure on the international taxation system, as business models change. Policy makers are currently struggling to find solutions which can ensure a fair and effective taxation as the digital transformation of the economy accelerates. Existing corporate taxation rules are outdated to address the changes that have occurred and continuing to occur. The current corporate income tax rules are based on having a physical presence in a country, without reflecting the value created by user participation in that jurisdiction. Such rules fail to capture the global reach of digital activities where physical presence is not a requirement anymore in order to be able to supply digital services. While TP rules are used to attribute the profit of multinational groups to the different countries, they do not reflect that digital business models that can vary significantly and have different characteristics than traditional ones in terms of how value is created. This may generate distortion of competition and cause a negative impact on the collection of tax revenues which is critical in the goverments’ on-going battle to control Covid-19. Some countries are proceedings unilaterally, by setting up domestic web taxes, while others – like the European union member countries –  are adopting a common legislative framework. Against this backdrop, understanding and sharing knowledge on how countries/multilateral organizations are addressing this topic from a tax perspective is material. The panel will analyze the current situation facing taxpayers and discuss possible solutions from different angles.


Riccardo Cajola
Managing Partner
Cajola & Associati

His practice is focused on Italian and cross-border transactional and commercial work, principally in the area of M&A, private equity and venture capital investments, corporate restructurings, and a variety of other general corporate transactions. Riccardo currently focuses on M&A and private equity investments in distressed companies and assets trapped in special situations, both in the corporate and real estate sectors. In addition, Riccardo frequently advises on tax related matters and represents on tax disputes and complex tax dispute resolution proceedings, about – for instance – challenges on group transfer pricing policies. He currently serves as President of the Supervisory Board of Epson Italia Spa and as member of the Supervisory Boards of several other domestic companies.


George Ribeiro
Ribero Hui
Hong Kong

George Anthony Ribeiro is one of the founding partners of Ribeiro Hui, which has offices in Hong Kong, Shanghai, Beijing and Shenzhen. George has advised local and international clients on numerous aspects of the law and practice in conducting business in Greater China, and with delivery of tailored solutions to achieve objectives. George’s experience and major practice areas covers Direct China investment, Mergers & acquisitions, Group restructure for tax/costs/operational efficiency, Regulatory compliance, Tax and multi-forum litigation. He has consistently been identified as one of Asia’s Leading Lawyers in the Asia Leading Lawyers Annual Survey. Due to his immense breadth of Greater China law and practice garnished from his over 30 years of practical experience, he has been invited to give speeches on Greater China law and practice at international conferences. George was the Co-Chair of the International Bar Association International Sales Committee for 2019-2020 and has held various offices at international legal associations such as the IBA, NYSBA and IPBA. He was appointed as a Notary Public in Hong Kong in 2020.

Alexander Puperter
Blomberg Pupeter Heil

Specializing in: Transformation and Restructuring, Tax Planning and Tax Structuring, Private Equity Investments, Corporate Law

Ron Parks
SMPP Legal

Prior to joining SMPP, Ron has nearly 20 years of tax and legal experience. He has significant experience in emerging markets, oil and gas projects, real estate development projects, cross border structuring, transfer pricing, M&A and corporate reorganizations. He has also acted as an adjunct instructor teaching business law, international tax law and international business transactions.

Ryousuke Kono
Oh-Ebashi LPC & Partners

Ryosuke Kono is a partner at Oh-Ebashi LPC & Partners. He represents clients in a number of complex tax litigation and administrative controversies. He also advises on tax matters in various types of domestic and cross-border transactions. His practice covers a wide range of tax issues, including transfer pricing, anti-tax haven rules (CFC rules), withholding rules, depreciation, permanent establishment (PE), customs duties as well as issues relating to cross-border restructuring, mergers and acquisitions and joint venture. He previously served as a Review Officer (International Examination) for the Review Division (Large Enterprise Examination) of the Osaka Regional Taxation Bureau, where he handled a broad range of complex tax issues.