International - Dispute Prevention Avenues for Permanent Establishments
- R.S. Critchley
- International Transfer Pricing Journal, 2017 (Volume 24), No 4
- 19 July 2017
The global way businesses operate and the measures proposed by the base erosion and profit shifting (BEPS) Project by the OECD have transformed the tax field in recent years. With a potential increase in disputes and lengthy, costly dispute resolution procedures (i.e. MAPs and arbitration procedures), there is an emphasis on measures to avoid disputes in the first place. This article focuses on instruments that permanent establishments (PEs) may have to obtain upfront certainty on the interpretation of domestic legislation or tax treaties, thereby avoiding disputes and ensuring a reduced risk of double taxation of profits.