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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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