Desmond Wang and Jamie Cook provided valuable research assistance. I stress that the views contained in this Article, including mistakes, should not be attributed to any of the foregoing individuals or institutions. INTRODUCTION Do digital platforms, operated by multinational companies (MNCs), give rise to new profit tax bases? Do they support new claims to, or new desirable international allocations of, taxing rights with respect to MNC profits? In the last two years, these questions have been forcefully raised by bold, new legislative proposals from the UK government, 1 the European Commission (EC), 2 and a number of European national governments including Spain, France, Austria, and others. 3 These governments have called for the international community to explore long-term strategies to reforming international business income taxation, such that taxing right over MNC profits could be reallocated to reflect the value contributed by users of digital platforms. They also announced the intention to adopt unilateral, "interim solutions" that do not require international consensus. These unilateral solutions deploy taxes imposed on revenues from various digital services, and are meant to prod nations into multilateral action. While the details of the proposed interim taxes vary, a subset of them, bearing sufficient resemblance with one another, are now associated with the label "digital services tax" (DST). Because the prospect