The rise of the digital economy and the substantial profits generated by some digital businesses, together with the opportunity for tax base erosion and profit shifting afforded by digital business models, have resulted in a call to update the international tax system to address the digital economy. Tasked with formulating an international approach, the OECD has yet to propose a viable reform package. In the absence of multilateral consensus, many jurisdictions have begun to formulate unilateral rules to tax the digital economy. The inconsistency of these rules is likely to increase the tax burden of digitalised businesses operating internationally.