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Protecting the tax base in the digital economyFor example, in Brazil and India, B2C e-commerce accounted foralmost one half of total e-commerce.In terms of e-commerce involving digital goods, services andintangibles, developing countries are net importers, especially asregards B2C transactions. 38 Cross-border B2C e-commerce has beengrowing in BRICS countries with the growth of the middle class andconnectivity to the global networks in these countries. 39 China ledall other countries in B2C and C2C purchases by the end of 2013. 40actions will account for about 5 per cent of all intercompany transactionsand retail sales by 2017: see World Economic Forum, Beñat Bilbao-Osario,Souitra Dutta and Bruno Lanvin, eds., “The Global Information TechnologyReport 2013 in a Hyperconnected World,” supra note 28, at 3.38The major exporters are developed countries such as France, Germany,the Netherlands, the United Kingdom of Great Britain and Northern Irelandand the United States of America. Brazil, China and the Russian Federationare among the top online retail importers. China was ranked number 1 inthe Global Retail e-Commerce Index in 2013, Brazil was ranked number 8,and the Russian Federation number 13. See yStats.com, Global Cross-BorderB2C E-Commerce (2014), available at http://www.ystats.com/product/globalcross-border-b2c-e-commerce-2014/;ATKearney 2013 Global Retail DevelopmentIndex, available at http://www.atkearney.com/consumer-productsretail/global-retail-development-index.39In 2013, the Internet penetration rate (number of Internet users per100 population) was 51.6 per cent in Brazil, 45.8 per cent in China, 15.1 percent in India and 61.4 per cent in the Russian Federation. World Bank (2014),“Internet users (per 100 people),” available at http://data.worldbank.org/indicator/IT.NET.USER.P2.40In 2013, the gross merchandise value of e-commerce represented byB2B e-commerce and traditional e-retailing was almost RMB 10 trillion. Forthe next five years, the growth rate of online shopping, B2B e-commerce oflarge enterprises and SME B2B e-commerce is predicted to be 22 per cent,12 per cent and 25 per cent, respectively. China’s e-tail (B2C) market wasthe second largest in 2012 and 2013 and was forecast to surpass the UnitedStates in 2014. In particular, the proportion of mobile commerce is expectedto grow from 8.5 per cent in 2013 to 24 per cent in 2017. See KPMG, “E-commercein China: Driving a new consumer culture,” (2014) No. 15 China 360,available at http://www.kpmg.com/CN/en/IssuesAndInsights/ArticlesPublications/Newsletters/China-360/Documents/China-360-Issue15-201401-Ecommerce-in-China.pdf.419

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