Because of electronic commerce (e-commerce), almost no physical contact is made between the consumer in one country and the seller located in another country. There is no physical location to which the Source State may be able to impute the income and, accordingly, no PE could be considered to exist in those cases.178 The Internet constantly becomes a tool to manage business without the need of a physical interface in the source country and, thus, avoids potential qualification of the enterprise as a PE.