The essay says service-heavy economies, including digitally delivered exports (about 7% annual growth, now 56% of global services trade), create real value without a factory, warehouse, or other physical anchor tax officers can see.

A Nairobi consultant paid by a European client is the example: residence, source, and permanent-establishment rules still need a place of activity, but the traces are split across payments, platforms, and borders—UNCTAD’s “servicification.”

The fix argued is not more raw data but linking what exists—registrations, payments, customs, e-invoicing, shared identifiers, and cross-border exchange—so states can map economic relationships rather than rely on physical presence.

As developing economies become increasingly service-based, they may be generating economic value faster than they are generating fiscal visibility.

A tax collector enters a factory and immediately knows where he is. There are machines, workers, inventories, electricity consumption, suppliers and trucks. Economic activity has a physical address. It occupies a space, consumes inputs and leaves a visible trail.

Now imagine that same tax collector trying to identify taxpayers and taxable activity in an economy mostly driven by services. He will find consultants working from a laptop, designers selling to clients abroad from a bedroom, programmers paid through a global platform, engineers advising companies thousands of kilometres away, or logistics intermediaries organising a shipment without ever touching the goods. The value all these activities generate is real. What has disappeared is not the activity, but its........

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