Why the OECD should not widen permanent establishment definition

July 23 2012

As many governments face significant financial deficits, taxpayers are seeing an increase in efforts by fiscal authorities to tax the activities of foreign companies in their jurisdiction. Expanding the definition of what is considered a permanent establishment of a foreign company is part of this trend.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Request Access or Login

Topics

more across site & shared bottom lb ros

More from across our site

Transfer Pricing

TP in Peru: where global profitability policies meet a transaction-by-transaction regime

Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments

Miguel Puga, August 06 2026

Direct Tax

How ESR and pillar two are converging across the GCC

Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test

Hany Elnaggar, August 05 2026

Transfer Pricing

Alphatax broadens TP portfolio with double acquisition

The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed

Sam Sholli, August 04 2026

Indirect Tax

From advisory to advocacy: why Gunjan Prabhakaran chose litigation

The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another

Tom Baker, August 04 2026

Direct Tax

Beyond the headlines: How ex-government talent strengthens top tax practices

Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings

Sam Sholli, August 03 2026

Indirect Tax

Why Peppol is the right strategic choice for UK e-invoicing

Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol

Nitin Agarwal, August 03 2026

Direct Tax

A taxing week: Could this be the new UK PM’s most important decision?

As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues

Chris Danes, July 31 2026

Direct Tax

Pillar two has eroded but not imploded: tax academic

Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour

Sam Sholli, July 30 2026

Transfer Pricing

Brazil’s new customs valuation tools: TP documentation becomes harder to ignore

Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions

William Roberto Crestani, July 30 2026

Direct Tax

Grant Thornton sets eyes on big four with $5bn CBIZ acquisition

The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition

Sam Sholli, July 29 2026