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Source-based taxation of e-commerce income: A study of the unresolved issues

Ndonga, D. and Riegler, A.M. (2019) Source-based taxation of e-commerce income: A study of the unresolved issues. Journal of Business Law (6). pp. 459-480.


Rapid progressions in cross-border e-commerce has revolutionized international trade and made it possible for businesses to transact in a borderless Internet environment. However, most international tax treaties still apply source-based taxation principles, including the permanent establishment concept, in taxing income derived from international commerce. This article examines whether source-based taxation remains theoretically valid in the territorial taxation of cross-border e-commerce income. It analyses the application of the permanent establishment concept to e-commerce corporate income and reviews some of the existing challenges and the current responses to these challenges at the academic and international level.

Item Type: Journal Article
Murdoch Affiliation(s): Law and Criminology
Publisher: Sweet & Maxwell
Copyright: © 2020 Sweet & Maxwell and its Contributors
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