The theoretical foundations and continued rationale for source-based taxation in an electronic commerce environment

Abstract

This paper is directed at analysing the theoretical foundations and rationale for source-based taxation and argues that these principles remain valid despite changes brought about by globalisation, including the increased incidence of transactions that occur via electronic commerce. The analysis in this paper is not concerned with how source is defined, but rather at establishing that source-based taxation continues to be theoretically justifiable for income that arises from international transactions which are conducted in a globalised business environment, including those that occur through the agency of electronic commerce.