Volume 42 (2014) / Issue 5

Tatiana Falcão, Bob Michel, 'Assessing the Tax Challenges of the Digital Economy: An Eye-Opening Case Study' (2014) 42 Intertax, Issue 5, pp. 317–324


The article demonstrates how under the current state of world affairs, a digital service provider could render its services to different jurisdictions without actually meeting any of the OECD's current substantial presence tests that would legitimize the imposition of a tax in the country of source. It proposes a case study to illustrate how, by mere application of the current non-abusive rules contained in the OECD Model Tax Convention, a digital service provider could render a multitude of services to different countries without actually paying any taxes in the country where the revenue arises.

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ISSN: 0165-2826
ID: TAXI2014033