Digital commerce, which was in its infancy, accentuated during
the Covid-19 pandemic. The ability to provide goods and services
from far-flung locations, as never-before, complicated and
completely frustrated existing regulatory frameworks, designed to
address traditional commerce. The pressing priority undoubtedly
involves an overhaul of the regulatory framework, while not
impeding the trajectory of digital commerce.
In International taxation framework, digitalisation obviated
nexus between income producing activity and location, consequently,
rendering physical presence based rules of taxation obsolete.
Further, it made characterisation and consequent taxability of
receipts of a non-resident technology company
("NRTC") an onerous task.
