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Brian J. Arnold2.3 An overview of the domestic laws of developingcountries with respect to the taxation of income fromservices derived by non-residentsIn this section, the domestic laws of developing countries with respectto the taxation of income from services by non-residents are examinedin terms of the framework of analysis described above. The discussiondoes not focus on the treatment of income from services in anyparticular country or countries, although occasional references to therules in particular countries are made by way of example.First, the jurisdictional basis for taxing non-residents on incomefrom services is simply a manifestation of the scope of a particularcountry’s domestic tax rules. Although there are no effective limitationson domestic taxation of non-residents under international law,there are practical constraints on the ability of a country to enforcetaxes imposed on non-residents in the absence of some connectionwith the country.Second, in several countries the rules vary depending on thetype of services involved. Some countries treat income from servicesderived by non-residents in the same way as other business incomederived by them, although even these countries often have specialrules for certain types of specialized services, such as internationalshipping and transportation, insurance, construction and entertainment.Surprisingly, even for countries that treat income from servicesdifferently from other business income, few of them have any statutorydefinition of services. 21 Some South American countries have judicialor administrative pronouncements concerning the meaning of services.In general, the meaning is quite broad and includes a wide range21Similarly, the GATS does not define the term “services.” The RussianFederation’s tax code contains a statutory definition of services as actionswith intangible results consumed in the course of the actions that confer benefitsto the customer. The definition excludes actions with tangible resultsprovided to the customer, financial rental, licences of intellectual propertyand assignment of rights. Despite the definition, there is considerable uncertaintyabout the meaning of services. See Dzhangar Dzhaichinov and PetrPopov, “Russia,” in International Fiscal Association, “Enterprise Services,” inCahiers de droit fiscal international, supra note 7, 579 – 91.56