This article reveals lessons from history on source taxation in the digital economy, suggesting new approaches like digital services taxes.
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.
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O. Kácser (2025) studied this question.
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