The so-called IV industrial revolution, brought with it the electronic commerce or e-commerce, this new commercial landscape has generated the need to establish a regulatory regime to regulate these commercial and tax relations. Given the lack of territoriality in e-commerce, States, public administration and tax administration worldwide have lagged behind in the face of these commercial dynamics driven by the Internet. Being one of the options to avoid BEPS, the creation of a global digital tax, however, this initiative of some countries presents as any type of public policy barriers that need to be considered.