The OECD Work Programme published in May of this year under the OECD/G20 Inclusive Framework on BEPS aims to achieve a consensus solution to the problems of taxing the digital economy. The OECD Work Programme is broad in scope and considers radical departures from long established rules for international taxation, for example current transfer pricing…

Taxation of the digital economy is one of the more difficult and contentious issues in international taxation. There are several strands to this complexity. One strand is profit attribution for enterprises trading across different tax jurisdictions. Yet, several countries have introduced or propose to introduce a tax on MNEs in the digital sector known as…