The example you give is a clear violation, both in the past and the present. The author's feet are clearly in Italy and hence subject to Italian taxation (unles

The example you give is a clear violation, both in the past and the present. The author's feet are clearly in Italy and hence subject to Italian taxation (unless reciprocity agreement). That's not up for debate. This corresponds to the "latter" option I proposed before where the sysadmin travels around. This we are definitely aligned. Upon reflection, I should not have said "an open question". Rather, I should have said that many feel that the spirit and intent of the law should be revisited. For many, the feet test is about resources utilization. Using electricity, internet, housing, etc. In the author example, the author is clearly making a choice to live at that hotel. Back when the law was written, I think this would have covered most cases. However, now, the modal case are "digital nomads" where the normal thing is to not spend more than 1 week - 1 month in a single place. Oftentimes, the destination doesn't matter, but the journey. In the extreme, imagine spending 2 days in every country in the world, in perpetual motion. This has always been a possibility and the law covers this case (as we both know) but I think people are beginning to question if it makes sense given the new distribution brought by the internet. To come back to the sysadmin example, the point was that the sysadmin is utilizing the same global resources except for maybe an additional epsilon as they move around to the different localities. Many feel that the locality does not provide anything in return for the right to tax the income.