The income tax treatment of electronic commerce transactions derived from a source within Switzerland…

… Policy issues
Since, as we have seen, a server will as such be characterized as a PE only in very limited circumstances, taxation of electronic commerce transactions will in most cases be based on the residence of the taxpayers involved.
So far, the growth of electronic commerce has not prompted a re-examination
of the existing source concept in Switzerland or of the existing threshold of
source taxation in this country. This could also be due to the fact that Switzerland applies the exemption method in this context and thus should exempt profits attributable to the foreign PE. Taking into account the extended possibilities of moving and manipulating the server, a broad interpretation of the PE concept would open the door to tax planning. There is no policy reason to attribute a part of profits of “offshore” servers, which have been placed in a specific tax haven only for tax reasons.