Brevi riflessioni in tema di stabile organizzazione digitale: dalla bit tax all’utentecentrismo?

[Autom. eng. transl.] The digitalization of the economy poses the need to go beyond traditional “territory-centric” connection criteria between income and the state entitled to exercise one's taxing authority. This is because the activities economically, and fiscally, significant ones put in place by digital companies are independent, by their very nature, of the stable presence within a given territory. Therefore, if it is true, as it is, that said canons of territorial correlation developed on the basis of the experience of traditional economies cannot be applied in relation to those digitized, at the same time, however, we must ask ourselves if it is possible to find at least one criterion that is halfway between connecting factors applicable to traditional economies and the necessary innovation of these that digitization requires. In this perspective, recalling the essential characteristics of an elaborate tribute, albeit in ancient times, for the sole purpose of taxing interactions between users and digital platforms (so-called bit tax), we will question the possibility of to borrow from the structure of this tax the possibility of anchoring the taxation of economies to the place where the digital service is used by users, finally highlighting i potential benefits that could follow from this choice.