Decoupling Source Taxation from Physical Presence: Historical Precedents and Lessons for the Digital Economy
New
Journal
International; OECD
Bulletin for International Taxation 2026 (Volume 80), No. 1
This article explores historical efforts to decouple source taxation from physical presence, tracing the permanent establishment concept. Drawing on early mechanisms, it highlights lessons for today’s “scale without mass” digital economy, shaping approaches like significant economic presence, OECD’s Pillar One, and digital services taxes.