Cloud Computing: Difficulties in Applying Current and Proposed Nexus and Profit Allocation Rules in a Cross-Border Scenario

This article discusses the international tax challenges with respect to business profits arising from the digital economy using the cloud computing service model. In particular, it examines issues that arise from the OECD Model Convention (2017) and other OECD documents, the EU Proposal for a Directive on a Significant Digital Presence and the OECD Secretariat Proposal for a “Unified Approach” under Pillar One.