La dimensione fiscale europea del mercato e delle imprese digitali: tra logica incentivante e perdita di gettito negli Stati membri per una nuova fiscalità unionale

This research aims to investigate the taxation of the digital economy, cornerstone of the debates that are taking places in this period in relation to the national, international and european tax law, conveying the attention of the domestic and foreign doctrine, practice, jurisprudence and politics. The dissertation is composed by four chapters. With the first one an actio finis regundorum is carried out to define the boundaries of the digital economy, in attempting to show that it is not easy to subsume the digital richness into well-known categories. The second part of the research analyzes the main taxation structures focusing in particular on the tax chargeable event (what to tax?) assessing his adaptability to the digital economy while imaging possible variations in the light even of the proposals done by the doctrine. In the third chapter the examination will deal in particular with the territorial profile (where to tax?).Therefore, the last section is devoted to the study of which normative level is the most appropriate for the taxation of the digital richness (who to tax?). Through the examination of the various sources of law, the hypotheses of an euroepan taxation of the digital economy will be advanced, taking into account the proposals put forward on international and national level, trying to identify an essential scheme (how to tax?). Finally, on a general level, it will be recalled that this issue could became the centrepiece of the European Union's political history, as the construction of the digital Single Market could give rise to a new taxation that is truly european with the further aim to foster and encourage the birth and development of european digital businesses, through a progressive level playing field.