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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Both Germany’s NIS2 and the EU AI Act now determine whether a tax function can meet its obligations – and both can make management personally accountable
Originators, loan purchasers and securitisation vehicles may need to revisit servicing agreements and pricing after a key judgment narrowed the VAT credit management exemption
The allegations against Deloitte Cyprus raise uncomfortable questions about how far the big four can distance themselves from misconduct at member firms