In case of cross–border transactions, especially the ones in which the income arises in contracting state to resident of other contracting state, the domestic tax laws of the contracting state define the degree up to which the contracting state seeks to levy charge of tax on resident of other contracting state.
An e-commerce transaction involves a server, place where website is controlled and updated and jurisdiction where end customer enters into e-commerce transaction through aforesaid website. Server is nothing but storage and hosting medium for a particular website. Hence, it is server which stores the websites and hosts it over an internet.’