Will implementing the UN FACTI Panel’s principle-based approach as part of the formulation of taxing and profit allocation rules under the OECD BEPS’ policy driven approach give these rules the legitimacy needed for equitable and fair enforcement?

This paper addresses the challenges of taxing the digital economy and offers potential solutions towards aligning the digital economy with the tax rules governing traditional businesses in the interim while specific digital tax laws are being deliberated on at a political level. The methodology...