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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems