Technological development has rapidly increased the mobility of labour, undermining the implicit assumption that employees will be physically located in the same jurisdiction as their employers, and calling into question the basis on which taxing rights over employment income are allocated within the international tax system. To date, the literature on reform in this area has been dominated by the developed world. This article brings a developing world perspective to the debate. The authors argue that such reform needs to consider not only pragmatism but also inter-nation equity to achieve legitimacy.