The relationship of the territoriality of corporate taxation and the economy[Les rapports et regards de la territorialité de l'impôt sur les sociétés avec l'économie]

The consequence of the revolution of internet and digital is the erosion of taxe bases. The creation of value has shift from the production of tangibles to intangibles. This resulted in the disparition of tax bases. But the recognition of this phenomenon does not imply to radically question the relevance of tax instruments inherited from the fordist period. It may simply lead to the proposition of new rules or new taxes aiming to compensate revenue losses. The first part of the paper is devoted to a review of the economic approaches of the taxation of digital for which the mobility of activities and the erosion of tax bases are essential issues. This immediately puts the tax issue on an international level and raises the question of the taxation of rents massively captured by digital companies. In the second part, and after a brief presentation of the main characteristics of the tax system inherited from the Fordist period, we study the main developments that took place during this period. Finally, we emphasize the main lines of the changes affecting capitalism. They cause the present lack of adjustment between the economic bases of capitalism and the tax system. This new capitalism works by deterritorializing the tax bases.