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The ongoing digital transformation poses enormous challenges to current tax law. This is, because value creation through intangibles raises problems to two core paradigms of international tax rules: where to tax and what to tax. In order to solve these problems, the European Commission published two proposals, a so-called interim tax and a comprehensive solution. In this blogpost, Pola Schneemelcher assesses the proposals and makes the case that they do not sufficiently address the crucial question of how to value data.