The Shift from Physical Nexus to Payment Gateway Extraction

Podcast: Offshore Tax with HTJ.tax · htjtax

Opublikowano: 2026-10-27

The Shift from Physical Nexus to Payment Gateway Extraction For decades, international tax treaties generally protected business profits from source-country taxation unless the foreign enterprise had a Permanent Establishment (PE) in that country, subject to the specific treaty provisions. That traditional framework is under pressure as governments seek greater taxing rights over cross-border services, including services delivered remotely without a substantial physical presence in the customer’s country. The United Nations Model Tax Convention provides important context. Article 12A addresses fees for technical services, Article 12B covers automated digital services, and the newer Ar...