Summary The article introduces a new framework for international taxation reform to appropriately accommodate the activities of multinational corporations that are digitizing their economies. Prof. Yoshimura examines the theories underlying the taxing rights of market countries and the implications these theories have for the local tax debate and its future. While the changes in international taxation rules are not immediately applicable to local taxation systems, it should be considered that the development of information and communication technology requires modifications to the standards on which taxation rights have been based, a point which the two have in common.