Tax authorities worldwide are struggling to adapt traditional systems to a digital, borderless economy. Modern business models increasingly rely on cloud computing, Software-as-a-Service (SaaS), digital platforms and integrated payment ecosystems. These developments have fundamentally reshaped how value is created and where it is deemed to arise.
At the heart of this debate lies the definition of “royalty.” Traditionally, royalties referred to payments made for the use of intellectual property such as patents, copyrights, trademarks, and industrial know-how.
