Interpretative Issues Arising from the Definitions of Permanent Establishments under the GloBE Model Rules

Journal
Patti, G.F.
International; OECD
Bulletin for International Taxation 2024 (Volume 78), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The GloBE Model Rules on Pillar Two contain certain specific definitions of permanent establishments, which apply depending on the features of the foreign place of business of a given enterprise. The definitions refer to treaty law, but the meaning and the effect of those references are not always entirely clear.