The discussion on adequate taxation of the digital economy is primarily concerned with the “fair" allocation of the companies’ tax substrate among states. At OECD and EU level, there are several proposals on the taxation of the digital economy and the allocation of taxation rights. Taxation according to value creation was declared to be the guiding principle of fair allocation. This article addresses the question of whether value creation is suitable for implementing intergovernmental tax fairness at EU level. It follows the article on the implementation of intergovernmental tax justice at OECD level published in SWI 2022, 557.
