Abstract:
<jats:p>I chose to write on a theoretical jurisprudential topic which, in my view, is anchored to a practical problem. In fact, with the rise of the digital economy, it has become the most critical functional problem in the tax world of the 21st century. This article attempts to establish a justification for the taxation of income earned by highly digitalised businesses in the source or market jurisdiction. The article explains why this theoretical question is such an important issue in international tax.</jats:p>