The digital revolution has transformed business models, entire economies and the lives of people around the globe. It has also tested the concept of traditional corporate tax rules, designed largely in the first half of the 20th century. These rules are now unfit for our increasingly digitalised and globalised world.
As the business models of digital companies have increasingly allowed them to create value in countries without any physical presence, traditional tax concepts such as residence, nexus and
profit allocation seem to have become out of date. Moreover, as international commerce has transcended national borders, the digital world has exploited gaps in the dated tax system to avoid
taxation on cross-border transactions.