The VAT treatment of cloud computing: legal issues and practical difficulties

ABSTRACT In this contribution, the author deals with some selected legal and practical issues related to the VAT treatment of cloud computing technologies. Cloud computing is major a phase of development and expansion, and is likely to have new tax challenges in the future. In particular, in the first part of the contribution some aspects of the relationships between cloud computing and the ‘VAT concepts’ of fixed establishment and immovable property are discussed. In the second part, some practical issues deriving from the localisation and identification of the customer are presented with a special eye on the most recent OECD proposals.