This annex summarises the content and output of the previous work on electronic commerce. Specifically, it presents the work that led to the 1998 Ministerial Conference on Electronic Commerce in Ottawa (Ottawa Conference) and its main outcomes. It then describes the follow-up work carried out in relation to tax treaty issues and to consumption tax issues.

The simplified examples below are based on what a number of tax administrations have observed. They are intended to provide an illustration of ways in which the implementation of business models through legal and tax structures may place pressure on the existing international tax framework. They are not exhaustive, and do not pretend to reflect the full scope of structures that may be used to achieve base erosion and profit shifting (BEPS).