In the midst of base erosion and profit shifting (BEPS) and a call for corporate taxation to be hauled into the 21st century, the digital economy is a big focus for tax policy crafters. Sophie Ashley looks at the arguments surrounding the issue of digital permanent establishments (PE), and why some countries are keener than others to see the attitude to taxing them change.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap