The digital economy as a product of the Internet and information and communication technologies has today become an imperative of the modern economy. The concept of digital economy is today widespread around the world and is most often associated with certain positive changes such as new ways of doing business activities, emergence of new business models and appearance of social networks that have changed the way social life takes place. Digital businesses that are aware of the benefits of digital transformation have gained big competitive advantage over traditional industrial economies. On the other side, the digital economy poses challenges to tax authorities in the context of direct and indirect taxation. International taxation rules that were created in the last century are not adequate for digital economies. The digital economy that takes place online knows no physical boundaries and allows entrepreneurs to do business and reach to a large number od consumers around the world without the need for a physical presence. The existing rules on taxation of corporate income are not applicable to digital companies because they do not distinguish the place of creating profit from the place where the profit will be taxed. All this creates the possibilities of BEPS practice, which implies the erosion of the tax base and profit shifting into tax heavens, known also as aggressive tax planning. These problems are being addressed by the European Union and the Organization for Economic Co-operation and Development (OECD) together with the countries G20. Their priority is to enable fair and efficient taxation trough proposals and potential solution, by which digital companies would finally participate in the fair share of paying taxes that are in accordance with the profit they really make.