Permanent Establishments and Action 1 on the Digital Economy of the OECD Base Erosion and Profit Shifting Initiative – The Nexus Criterion Redefined?

The author, in this article, examines the proposals made by the OECD in relation to Action 1 of the Base Erosion and Profit Shifting initiative regarding the digital economy with particular focus on the various changes suggested in relation to the concept of a permanent establishment and the nexus idea enshrined in article 5 of the OECD Model.