Comment on Selected Aspects of Proposals in Public Consultation Document on Addressing the Challenges of the Digitalization of the Economy

Abstract

This comment was filed in response to the G20/OECD Inclusive Forum’s Public Consultation Document on Addressing the Challenges of the Digitalization of the Economy. The comment supports a re-alignment of the division of corporate income between source and residence countries that is not restricted to digitalized businesses. The comment seeks to contribute to the discussion by outlining a framework for taxing a nonresident taxpayer that is “heavily involved in the economic life of a jurisdiction without a significant physical presence” and includes description of a methodology for attributing income to a non-physical permanent establishment using existing income tax principles.