Permanent establishment (PE) is becoming more complicated as regulators find it hard to keep pace with a rapidly developing digital economy. Taxpayers regularly find themselves in difficulty trying to decide whether certain operations in certain jurisdictions constitute a PE but the consequences of getting it wrong could mean big transfer pricing adjustments for multinational companies. This selection of articles gives an overview of some of the most topical issues surrounding PE.
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While some may argue that heads should roll following KPMG Australia’s audit leak scandal, client and revenue data emphasises that tax team stability is paramount
A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation