Digitalization exacerbates the problems faced by the existing system for taxing corporate profit in an international context. It does so by making it much easier for all aspects of a company to be spread around the world: its shareholders and creditors, its operations and its consumers. As many of these problems ultimately stem from the fact that the existing system taxes companies in the location of their mobile factors, this article argues that a more direct and satisfactory response to these problems would be to move to a system in which companies are taxed where their immobile factors are located. The article considers two such possibilities: the location of shareholders and that of consumers. It also considers two specific issues which arise particularly in the context of digital companies, namely two sided markets and free usage.