unilateral

Introduction: A Tax System Out of Sync with the Digital Age For over a century, the bedrock of international taxation has been the principle of "physical presence." Multinational corporations generally pay corporate income tax (CIT) in jurisdictions where they maintain a physical footprint—factories, offices, or warehouses. However, the rise of the digital economy has rendered…

Introduction: A Tax System for the Analog Era For decades, the bedrock of international corporate taxation has been the principle of physical presence—the idea that a company should pay taxes where its factories, offices, and employees are located. However, the rapid ascent of the digital economy has rendered this concept increasingly obsolete. Today’s tech giants…