The article demonstrates how under the current state of world affairs, a digital service provider could render its services to different jurisdictions without actually meeting any of the OECD's current substantial presence tests that would legitimize the imposition of a tax in the country of source. It proposes a case study to illustrate how, by mere application of the current non-abusive rules contained in the OECD Model Tax Convention, a digital service provider could render a multitude of services to different countries without actually paying any taxes in the country where the revenue arises.
Intertax