Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/333576 
Year of Publication: 
2025
Series/Report no.: 
Research Paper No. 226
Publisher: 
South Centre, Geneva
Abstract: 
Digital businesses continue to grow and generate substantial revenue in market jurisdictions without maintaining a physical presence. They mainly rely on intangibles, user data and user engagement. International tax rules have not kept pace with these developments, leaving many jurisdictions unable to tax digital economic activity effectively. In response, countries have introduced national measures, such as Digital Services Taxes (DSTs), equalisation levies, and Significant Economic Presence (SEP) taxes, while continuing to engage in multilateral efforts. This paper examines how countries have implemented such measures. The study applies structured case studies of Colombia, India, Kenya, Nepal, Nigeria, and Tanzania. It analyzes the countries' legal frameworks, administrative practices, and revenue outcomes, while also identifying shared features and key differences in implementation approaches. The paper explores the conceptual foundations and theoretical justifications for taxing digital revenues at source, highlighting the limitations of current profit allocation rules that overlook the role of the market. Drawing from these country experiences, the study develops a peer learning framework based on emerging best practices while recognizing the challenges in implementation. The study then proposes pathways for harmonizing digital tax measures and outlines essential design elements to inform the development of the early protocol on the taxation of cross border services (which includes digital services) under the United Nations Framework Convention on International Tax Cooperation.
Document Type: 
Research Report
Appears in Collections:

Files in This Item:
File
Size





Items in EconStor are protected by copyright, with all rights reserved, unless otherwise indicated.