The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment. However, the thesis also argues that the way in which the source of income is defined needs to be reconceptualized because the application of source-based taxation under traditional principles may be rendered problematic in light of certain characteristics of electronic commerce that are significant from a tax perspective.

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• Introduction
• The Theoretical Foundations and Rationale for SourceBased Taxation
• The Definition of Source and Identification of Characteristics of Electronic Commerce Which Suggest a Need to Reconceptualise the Way Source is Defined
• The Need to Reconceptualise the Way Source is Defined for Active Business Profits under the Permanent Establishment Threshold
• The Need to Reconceptualise the Way Source is Defined for Passive Income
• Reconceptualising Source for Active and Passive Income – The Base Erosion Approach
• Reconceptualising Source for Active and Passive Income – The Refundable Withholding Approach
• Summary, Conclusions, Implementation of the Research and Future Outlook

Dr Dale Pinto is an Associate Professor and Head of the Taxation Department at Curtin University in Perth, Western Australia. He has published extensively in both national and international journals and has presented papers at several national and international conferences. He was the inaugural winner of the Australian Commissioner of Taxation‘s Award for Research in Taxation, a prestigious award for research scholarship in taxation.

The mission of the International Bureau of Fiscal Documentation is: “[T]o maintain a knowledge centre providing information about and explanations of international taxation and promoting the study of taxation in general” (Art. 2 of the articles of association). True to this mission, and aware that access to doctoral theses is often limited, IBFD has taken the initiative to make available to a wider public a series of books based on doctoral research, meeting the highest academic standards.

Only contributions that enhance the international academic tax debate are accepted. In order to ensure high quality, every thesis published in this series has been reviewed by academic members of the Board of Trustees, senior IBFD research staff or prominent tax academics worldwide. The series aims to cover all aspects of comparative and international taxation, not only in respect of income tax, but also in respect of VAT and of inheritance, estate and gift taxes.