Cloud computing may facilitate MNE tax avoidance

Use of cloud computing makes it easier for a multi-national enterprise to avoid having a server (viewed as a potential permanent establishment) in a source jurisdiction and also may facilitate disguised transfers of intangibles under cover of the Cloud.

Neal Armstrong.  Summaries of Mateusz M. Krauze, "Impact of Cloud Computing on Permanent Establishments Under the OECD Model Tax Convention," Tax Management International Journal, Vol. 44, No. 3, March 13, 2015, p. 131 under Treaties – Art. 5, Art. 9.