Ending temporary guidance on tax residency adds to PE uncertainty

Danish Mehboob

September 21 2020

Ending temporary guidance on tax residency adds to PE uncertainty

Taxpayers are bracing for profitability and substance challenges because temporary tax guidance on permanent establishment (PE) issues will end and most governments are avoiding discussions on lasting measures that can limit tax exposure.

Unlock this content.

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

To unlock this content:

Take a Free Trial or Login

Topics

Danish Mehboob

Senior Reporter ITR

Danish reports on all matters of direct tax and BEPS. He covers a range of tax issues in these areas and what multinationals are doing to manage the tax burdens. Danish also specialises in tax technology and data management.

more across site & shared bottom lb ros

More from across our site

Direct Tax

WTS aims to capture PwC’s former francophone African footprint

WTS Global is also vetting new potential member firms in Algeria, Cote D’Ivoire and Benin, Kelly Mgbor tells ITR in an exclusive interview

Tom Baker, May 05 2025

Direct Tax

This week in tax: EU mulls pillar two revisions to placate US

The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign

Tom Baker, May 02 2025

Transfer Pricing

Bilateral APAs have their moment

For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality

Ralph Cunningham, May 01 2025

Direct Tax

Baker McKenzie picks up former US Treasury deputy Scott Levine

Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution

Tom Baker, April 30 2025

Direct Tax

Legal Benchmarking Group acquired by Triple Private Equity

The deal to acquire ITR's parent company is expected to complete by the end of May 2025

Tom Baker, April 29 2025

Direct Tax

Meat multinational JBS accused of dodging $442m in taxes

JBS, the biggest meat company in the world, allegedly used Luxembourgian ‘mailbox companies’ to avoid taxes between 2019 and 2022

Tom Baker, April 28 2025

Direct Tax

Australian tax adviser imprisoned for operating while unregistered

Despite the conviction of Jessa Dabalos, the Tax Practitioners’ Board’s investigative work continues with five outstanding PwC scandal probes

Tom Ravlic, April 28 2025

Direct Tax

Female hand with megaphone on white background

Why in-house tax teams should do their own PR

Heads of tax need to push their teams forward as strategic business advisers to add value across their organisations, says Sandy Markwick

Sandy Markwick, April 25 2025

Direct Tax

This week in tax: Elon Musk and Treasury secretary clash over IRS leadership

Scott Bessent reportedly felt undermined by Musk naming Gary Shapley as acting IRS commissioner; in other news, Baker Tilly will combine with a top 15 US firm

Tom Baker, April 25 2025

Transfer Pricing

India’s record APAs a win for government efficiency: experts

The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR

Tom Baker, April 24 2025