Since the advent of the internet and advancement of technology,
the conduct of business worldwide has seen significant changes.
Almost forgotten are the days when businesses and organisations
needed to have a physical presence in the countries where they
operated. Large corporations such as Google, Amazon, Twitter,
and Facebook now have a global reach without
needing to set up shop in all the countries where they operate. The
goods and services offered by such organization are digital,
enabling them to bypass the need to have a fixed base.
For governments, foreign or non-resident companies
("NRC") without a fixed base in their territories, but
clearly providing services into their territories through the
internet posed a tax and regulatory challenge. Most governments had
outdated laws that made it difficult to tax the enormous revenues
generated remotely from their territories by companies based in
other territories.
