Domenico Imparato (University of Hamburg – Institute of Law and Economics; University of California, Berkeley; University of Chicago), Reuven S. Avi-Yonah (University of Michigan Law School), and Karen Sam have posted Data Centers as Engines of Corporate Tax Base Restructuring on SSRN. Here is the abstract:
The article examines how data centers and AI infrastructure are reshaping international taxation by tying an increasing share of corporate value creation to immobile infrastructure. It considers the implications for taxing rights, sourcing, and future corporate tax reform.
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Lawrence Solum