Digitalization affects the entire global economy. The impact of this new technological wave can neither be ring-fenced to specific sectors of the economy nor be circumscribed to specific countries or regions. As a consequence, the use of new digital technology has not only transformed traditional business models but has also enabled the appearance of new digital-based business models that pose challenges to how economies have traditionally been taxed. A major breakthrough has been the ability to conduct business activities in a territory without having a physical presence there; in addition, the increasing reliance on intangibles has made it more difficult to differentiate value across different business functions, risks, and assets.