Document Type

Book Chapter

Publication Date


Source Publication

Li, Jinyan, Chapter 8: Protecting the Tax Base in a Digital Economy, UN Handbook - Protecting the Tax Base of Developing Countries (2nd ed)


BEPS; Digital economy; Permanent establishment; Source of income; Developing countries


Protecting the tax base in the digital economy is Action 1 of the Organisation for Economic Co-operation and Development (OECD) project on Base Erosion and Profit Shifting (BEPS). The reason is simple: “International tax rules, which date back to the 1920s, have not kept pace with the changing business environment, including the growing importance of intangibles and the digital economy.” They can no longer distribute taxing rights fairly among countries and adequately define a country’s tax base.

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