Introduction

International taxation is undergoing the most tremendous overhaul of the last 100 years. New standards have been identified at international level[1], bilateral tax treaties are re-negotiated in a multilateral context [2], discussions are ongoing on the next changes[3]. The outburst of the transformation is usually identified about five years ago, when the OECD launched its Base Erosion and Profit Shifting (BEPS) Project, in 2013. However, the change had in fact started much earlier, when new technologies began revolutionizing our every-day lives. Distances shortened. Time intensified. A new world order arose, where virtuality is the new reality and ideas the new gold.

In lig...