Abstract: The digital era provides new opportunities for innovation and economic growth. Fiscally, it creates opportunities for tax administrations to reduce tax evasion. On the other hand, the changing business models create international pressure on the tax system. The current requirements were established at the beginning of the 20th century for traditional companies, based on the principle of taxing profits where value is created. For digital activities, physical presence is no longer necessary in order to provide services. Thus, two major questions arise: Where do we tax?, in the case of a company with limited or no physical presence, and What do we tax?, in the case of a digital business plan based on knowledge, data and intangible assets.