Taxation in cloud computing: Direct taxation aspect

Computing resources are necessity anytime and anywhere just as electricity and water. Cloud computing, which are aimed mainly at persons who need the resources, provides various solutions through different service and deployment models. Service providers who offer these services within commercially successful business models push the limits in terms of basic concepts and rules of tax law. In this context, income categories and permanent establishment are among the most discussed and queried issues. This study focuses on income characterization and permanent establishment which are two of the problems regarding taxation of income derived from cloud computing services. In this regard, in the first section of the study, prominent aspects of cloud computing in terms of tax law are examined. In the second section, problems encountered in cloud computing services within the scope of income characterization and permanent establishment rules are scrutinized in detail. After discussing the proposals that have the potential to solve the above-mentioned problems in the third section, our conclusion from the study and findings about solutions are given in the conclusion section. It must be noted that this thesis is the product of research conducted in Vienna University of Economy and Business Institute for International and Austrian Tax Law, Austria with the "TÜBİTAK 2214/A Abroad Doctorate Research Grant Program".