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be part of the cost-benefit analysis of any digital transformation program. 360 It may also be difficult to meaningfully evaluate the true state of a digitalization of specific tax administrations. Such evaluations, which are frequently undertaken by third parties such as donor agencies or non-governmental organizations, are often primarily focused on quantitative indicators, which might not accurately represent success. Furthermore, because tax administrations do not benefit directly from these exercises and are the ones being evaluated, there is a possibility that they will not submit correct data. 361 Nonetheless, this year, the OECD has issued a progress report emphasizing that common, collaborative, digitally enabled and more real time approaches to the administration of common rules are becoming a central feature in the design of international tax rules. 362 2. Technological Empowerment in Tax Administration Adopting New Technologies Currently, tax and international tax policy debates are often driven by issues such as the amount of corporate tax paid by multinational corporations and its allocation across borders. Yet, we are experiencing an important phase in the ongoing digital transformation. 363 This technological transformation imposes on the law new concepts such as the cloud, robots, artificial intelligence, algorithm, internet of things, big data, digital presence, virtual permanent establishment, significant economic presence, blockchain, bitcoin, or intelligent assistants. 364 A question for the future is how can developing countries effectively acquire and integrate new technologies in their tax administrations to enhance efficiency and compliance, while addressing the associated legal, institutional, and capacity-building challenges . 2.2 Digital Taxation Systems General concept of digitalization of a tax administration primarily involves converting data and manual processes to digital and computer-supported formats, such as shifting from over-the-counter tax payments to electronic methods. It also encompasses advancing from basic digital tools to more integrated and automated processes. 365 Such new technologies may have a fueling effect on tax revenue generation linked to its ability to mitigate the challenges of delay, high administrative cost, evasion and corruption 360 Asian Development Bank, (2022), Launching a Digital Tax Administration Transformation: What You Need to Know (1st ed.), Asian Development Bank Institute, p. 24. 361 Vázquez-Caro J and Bird R, ‘Benchmarking Tax Administrations in Developing Countries: A Systemic Approach’ (2010) 9 E Journal of Tax Research 5, p. 6. 362 OECD, 2023 Progress Report on Tax Co-operation for the 21st Century. OECD Report for the G7 Finance Ministers and Central Bank Governors (2023) < https://doi.org/doi:https://doi.org/10.1787/d29d0872-en>, p. 3. 363 Russo R, ‘Reflections about the Implications of Platforms and Technology for Taxation and Taxpayers’ Rights’ in Weber, D (ed), The Implications of Online Platforms and Technology on Taxation (IBFD, 2023), pp. 1–3. 364 ILA, Sadowsky, M. e. c. White Paper 12 on Taxation: Taxing the Future (International Law Association (2023) , pp. 66–67. 365 OECD, ‘Supporting the Digitalisation of Developing Country Tax Administrations’ (2021), p. 143. 2.1

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