DIGITAL ASSETS DEFINED 
       Definition:
       An electronic record in which an individual has a right or interest. 
       -Does not include an underlying asset or liability unless the asset or liability is itself an electronic 
       record. 
       -Held online.
       -Arise out of establishment of digital businesses. 
       -Highly mobile and intangible ; physical presence of a company not necessary.
       -Exist in binary format and offer a right to use and this can range anywhere from motion 
       pictures, documents and any other type of data. 
       -The right to use is what makes data a digital asset. If there is no right to use then that data 
       cannot be considered a digital asset.
                     DIGITAL BUSINESS MODELS
       Subscription model ; users pay a subscription fee to have access to a service or 
         content on a website e.g. Netflix & Amazon.
       Advertisement model ; end users generate revenue by being exposed to advertising 
         in platforms provided by companies like YouTube and Yahoo.
       Access model ; content and app developers pay to have access to end users’ data 
         such as App Store.
       Peer to peer services ; provide users with ability to connect with people capable of 
         providing a service such as accommodation e.g booking.com , Airbnb.
       Online market places ; Amazon , Alibaba, Jumia
          Uganda;  Financial - Mobile money , bitcoin
                                Transport- Uber , Safe boda
                                Accommodation -Airbnb,Jumia travel, 
                                Online Market– Jumia ,OLX
                                
      LEGAL FRAMEWORK ON DIGITAL ASSETS 
                      IN UGANDA
     
      No specific rules for taxation of the digital economy.
     
      General rules under the Income Tax Act & VAT Act Apply.
     
       The OECD Model Tax Convention on Income & Capital is applicable
      THE CURRENT TREND IN DIGITAL ASSETS 
        Movement from physical services to digital services. 
        Increased use of Financial Technology (FinTech).
        Profit is created by charging usage or commission fees to service providers , users 
         and advertisers.
        Tom Godwin; 
          “In 2015 Uber , the world’s largest taxi Company owns no vehicles , face book 
          the world’s most popular media owner creates no content, Alibaba, the most 
          valuable retailer has no inventory and Airbnb the world’s largest 
          accommodation provider owns no real estate”.
               ISSUES IN TAXATION OF DIGITAL ASSETS
      International Taxation & Sourcing 
        
         Existing tax law developed primarily in a market of physical goods and in 
         – person services and today, services are increasingly being provided 
         digitally with minimal human intervention, through computer servers 
         instead of physical distribution chains.
        
         The questions that this creates are;
          • What is the Character of the income & how its taxed? ( royalty , rent or sale)
          • Who earned the income and where was it earned/sourced? (Location affects how 
           and where income is taxed under the source and PE principles. 
          • What is the machinery’s role in source rules? Is the place of performance of a 
           service the same as the server’s location? Can the source of the service be partly 
           in country X and part from the server’s location?
          • How should income be allocated between humans and machines in the supply 
           chain
          • Does it matter that a person in Country X programmed machines that are located 
           in country Y?
          • What impact do outsourced services have on place of performance?